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Focus on Landfi lling in Ireland
ENVIRONMENTAL PROTECTION AGENCY
An Ghníomhaireacht um Chaomhnú Comhshaoil
PO Box 3000, Johnstown Castle Estate, Co Wexford, Ireland
Telephone: +353-53-91-60600; Fax: +353-53-91-60699
E-mail: [email protected] Website: www.epa.ie
LoCall: 1890 335599
FOCUS ON LANDFILLING IN IRELANDThe Environmental Protection Agency
FOC
US O
N LA
ND
FILLING
IN IR
ELA
ND
The En
viron
men
tal Protectio
n A
gen
cy
49017 EPA Licensed Landfills Report - Part 2 - Cover.indd 1 18/08/2010 16:53
© Environmental Protection Agency 2010
Although every effort has been made to ensure the accuracy of the material contained
in this publication, complete accuracy cannot be guaranteed. Neither the Environmental
Protection Agency nor the author(s) accept any responsibility whatsoever for loss
or damage occasioned or claimed to have been occasioned, in part or in full, as a
consequence of any person acting, or refraining from acting, as a result of a matter
contained in this publication.
All or part of this publication may be reproduced without further permission, provided
the source is acknowledged.
Focus on Landfilling in Ireland
Authors:
Stephen McCarthy, Jim Moriarty, Denise O’Riordan & Gerard O’Leary
Published by the Environmental Protection Agency, Ireland.
ISBN No. 978-1-84095-368-8
07/10/250
Price: €15
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Focus on Landfilling in Ireland
Page 1
Environmental Protection Agency
Office of Environmental Enforcement (OEE)
List of tables 3
List of figures 3
Acknowledgements 4
Key terms 5
Executive summary 6
1. Introduction 10
1.1 Background 10
1.2 Legal & regulatory framework 10
2. Overview of landfilling in Ireland 12
2.1 Number & types of landfill 12
2.2 Environmental standards & enforcement 16
2.3 Legacy landfills 19
3. Landfill conditioning plans 21
3.1 Introduction 21
3.2 MSW landfills 21
3.3 Inert, mono & IPPC landfills 22
4. Treatment of waste & diversion of BMW 23
4.1 Introduction 23
4.2 Treatment of waste 23
4.3 Diversion of BMW 24
4.4 Implementation of waste treatment & BMW diversion 25
5. Waste Acceptance 28
5.1 Introduction 29
5.2 Pre-EPA licensing 29
5.3 Implementation of waste acceptance requirements 29
5.4 Specific waste acceptance issues 30
5.5 Guidance & standards 31
6. Landfill lining & leachate management 33
6.1 Introduction 34
6.2 Pre-EPA licensing 34
6.3 Implementation of lining & leachate management requirements 34
TABLE OF CONTENTS
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
7. Landfill cover & capping 38
7.1 Introduction 38
7.2 Pre-EPA licensing 38
7.3 Implementation of cover & capping requirements 39
8. Landfill gas management & odour control 42
8.1 Introduction 42
8.2 Pre-EPA licensing 42
8.3 Implementation of gas management requirements 42
8.4 Odour control 47
9. Monitoring 51
9.1 Introduction 51
9.2 Incidents & reporting 52
9.3 Surface water 53
9.4 Groundwater 54
9.5 Leachate 54
9.6 Landfill gas 55
9.7 Odour 55
9.8 Meteorological 56
9.9 Stability & topography 56
9.10 Noise 56
9.11 Dust 57
9.12 EPA enforcement of monitoring requirements 57
10. Closure, aftercare & financial provision 58
10.1 Introduction 59
10.2 Implementation of closure, aftercare & financial provision requirements 59
11. Action plan 61
References 69
Appendix 1 Legal & regulatory framework 72
Appendix 2 List of landfills 76
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
LIST OF TABLES
Table 2.1 Comparison of standards pertaining at open MSW landfills in 1995-1997 versus 2009 16
Table 2.2 Prosecutions relating to landfills 2001 to 2009 18
Table 2.3 Sites entered in the closed sites register (S.I. No. 524 of 2008) at the end of 2009 20
Table 3.1 Unlined inert and IPPC landfills 22
Table 4.1 BMW baseline, quantities landfilled, Landfill Directive % limits and converted to tonnage limits 24
Table 6.1 Landfills prosecuted by the EPA for inadequate leachate management – 2004 to 2009 36
Table 6.2 Urban wastewater treatment plants receiving MSW landfill leachate in 2008 36
Table 7.1 Descriptions of cover and capping terms based on EPA guidance manuals and EPA licences 39
Table 8.1 Landfills prosecuted by the EPA/ DPP for inadequate landfill gas management – 2004 to 2009 43
Table 8.2 MSW landfills using landfill gas to generate electricity in 2008 44
Table 8.3 Landfills for which the EPA received more than 20 odour complaints in 2009 47
Table 8.4 Landfills prosecuted by the EPA in relation to odour impact – 2004 to 2009 48
LIST OF FIGURES
Figure 1.1 Waste disposal at landfill in 2009 11
Figure 2.1 Numbers of open landfills -1985 to 2009 12
Figure 2.2 Number of landfills by type in 2009 12
Figure 2.3 Open landfills in 2009 14
Figure 2.4 EPA licensed closed landfills in 2009 15
Figure 2.5 Poor environmental management at MSW landfill in 1997 17
Figure 2.6 Good environmental management at MSW landfill in 2008 17
Figure 2.7 Non-compliances issued in relation to MSW, inert & mono landfills in 2008/2009 18
Figure 2.8 Electronic register and risk classification for closed landfill 19
Figure 3.1 IPPC landfill 22
Figure 4.1 BMW landfilled versus Landfill Directive % limits converted to tonnage limits 24
Figure 4.2 Overview of Waste Transfer Station 26
Figure 4.3 Treatment of waste – separation of cardboard and metal 26
Figure 4.4 Compost facility for treatment of waste 27
Figure 5.1 Landfill entrance including weighbridge 32
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Figure 6.1 Installation of liner at MSW landfill 37
Figure 6.2 Testing of welds on liner at MSW landfill 37
Figure 7.1 Capping at open MSW landfills in 2008 41
Figure 7.2 Installation of final cap at MSW landfill 41
Figure 8.1 Enclosed flare 44
Figure 8.2 Landfill gas utilisation plant 44
Figure 8.3 Methane emissions from landfill 1990-2008 45
Figure 8.4 Greenhouse gas emissions in Ireland 1990-2008 45
Figure 8.5 IT based data management system for interpretation of gas field balancing results 46
Figure 8.6 MSW landfill odour complaints versus total complaints in relation to waste and
IPPC licensed activities, 2004 – 2009
47
Figure 8.7 Monitoring of surface emissions from the flank of a landfill cell 49
Figure 8.8 Landfill surface emissions map showing results of monitoring 49
Figure 8.9 Changes in surface emissions at landfills surveyed in 2008 and 2009 49
Figure 9.1 EPA Landfill Manuals: Landfill Monitoring, 2nd Edition 52
Figure 9.2 Surface water management infrastructure 54
Figure 9.3 Landfill gas monitoring 55
Figure 9.4 Noise monitoring 56
Figure 9.5 Dust monitoring 57
Figure 10.1 Restored landfill cell 60
ACKNOWLEDGEMENTS
The report was prepared under the direction of Dara Lynott, Director, Office of Environmental Enforcement.
Comments on the report were also received from the other Directors of the Agency: Dr. Mary Kelly, Director
General, Ms Laura Burke, Mr Micheál Ó’ Cinnéide and Dr. Matt Crowe.
The cooperation of landfill operators in providing information for this report is gratefully acknowledged. Several EPA
staff provided input to specific aspects of the report: Brian Meaney, Jonathan Derham, Damien Masterson, David
Flynn, Donal Howley, Bernard Hyde, Regina Campbell, Pat Chan and Kevin Motherway. The assistance of Finnian
O’ Callaghan, Cork Institite of Technology, is acknowledged for his assistance in compiling and analysing data.
Maps in this report were produced by Tony Kent (EPA).
Photographs used in this report were provided by John Smith, Arthurstown Landfill and Brendan Wall, John
Doheny and Jim Moriarty (all EPA).
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
KEY TERMS
Landfill Directive Council Directive 1999/31/EC of 26
April 1999 on the landfill of waste
The Landfill Directive classifies landfills by waste type as
follows:
n Landfill for inert waste
n Landfill for non-hazardous waste
n Landfill for hazardous waste
However, for the purposes of this report it is more
useful to group landfills under the following headings:
n Municipal solid waste (MSW) landfills MSW
landfills accept predominately household and
commercial waste, and lesser quantities of
industrial waste. These landfills are limited to
accepting non-hazardous waste (with some
exceptions, see Chapter 5) and, therefore, are
classified as landfills for non-hazardous waste
under the Landfill Directive. MSW landfills were
predominantly operated by local authorities in the
past but private sector involvement has increased.
MSW landfills are licensed under the Waste
Management Act, 1996 (as amended).
n Inert landfills Stand-alone landfills for inert waste
licensed under the Waste Management Act, 1996
(as amended) and operated on a commercial/
merchant basis taking in inert waste from external
sources.
n Mono landfills Landfills licensed under the Waste
Waste Management Act, 1996 (as amended)
which accept single waste types from a single
source.
n Integrated pollution prevention and control
(IPPC) landfills Landfills associated with IPPC
activities and licensed under the Environmental
Protection Agency (EPA) Act, 1992 (as amended),
e.g. landfills for ash from power plants. In terms of
the Landfill Directive classifications, these include
both landfills for inert waste and landfills for non-
hazardous waste.
n Illegal landfills Landfills that operated illegally
and are now subject to EPA waste licences for
remediation/restoration.
Where a landfill is referred to as open in this document,
it means the landfill is accepting or open to accepting
waste for disposal during the time period in question.
Where a landfill is referred to as closed, it means the
landfill has permanently ceased accepting waste for
disposal. Landfills that are closed may still be accepting
waste for recovery, e.g. construction and demolition
waste for use in capping works.
Municipal waste means household waste as well
as commercial and other waste which, because of its
nature or composition, is similar to household waste.
Biodegradable waste means waste that is capable of
undergoing anaerobic or aerobic decomposition, such
as food and garden waste, paper and cardboard.
Biodegradable municipal waste (BMW) means the
biodegradable component of municipal waste. BMW is
typically composed of food and garden waste, wood,
paper, cardboard and textiles.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
EXECUTIVE SUMMARY
National and EU waste policy is based on the waste
hierarchy whereby waste should be prevented
and where this is not feasible, re-used, recycled or
recovered. The least preferred option is disposal to
landfill as it represents a loss of resources. The net
effect of waste policy is to encourage a move towards
a recycling and recovery society by diverting waste from
landfill through promotion of prevention, recycling and
recovery. The EPA publishes a comprehensive report
each year on waste generation and management.
This national waste report covers waste generated by
households, commercial premises, industrial operators,
as well as illustrating progress towards recovery
and recycling targets. In 2000 Ireland landfilled
approximately 90% of municipal waste arisings and
while this has reduced to 62.5% in 2008, Ireland
remains predominantly reliant on landfill in managing
waste.
The 1999 Landfill Directivea was a major milestone in
the regulation of landfills in Europe as it specified the
technical requirements for landfill design, operation
and closure, and set deadlines for the diversion
of biodegradable municipal waste from landfill.
It was later supplemented by a Council Decisionb
which specified the criteria for the acceptance of
waste at landfills. Landfills in Ireland were brought
under the regulatory control of the Environmental
Protection Agency (EPA) with the introduction of the
Environmental Protection Agency Act, 1992 and the
Waste Management Act, 1996. Many landfills closed
around this time while the remainder of operational
landfills became licensed by the EPA.
This EPA report provides an assessment of the
performance of landfills in Ireland against the
requirements of the Landfill Directive and outlines
the future challenges and issues for this sector.
a Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste.
b Council Decision (2003/33/EC) of 19 December 2002 establishing criteria and procedures for the acceptance of waste at landfills pursuant to Article 16 of and Annex II to Directive 1999/31/EC.
Report findings
Number and types of landfill
The number of open landfills decreased from over 200
in the mid-1980s to 48 in 2009. The 48 open landfills
in 2009 consisted of 30 municipal solid waste (MSW),
four inert, two mono landfills and the 12 landfills
associated with integrated pollution prevention and
control (IPPC) activities.
Consolidation in the MSW landfill sector is ongoing
with 29 MSW landfills remaining open at the end
of 2009 and more to close in the short-term. The
remaining MSW landfill capacity at the end of 2008
was approximately 24 million tonnes and represents
12 years capacity, i.e. to 2020.
Private sector involvement in MSW landfilling has
increased and accounts for approximately one third of the
sector in terms of licensed capacity and waste landfilled.
Regulation of closed landfills has become an increasingly
significant issue with 68 closed landfills covered by EPA
licences. In addition, there are over 300 local authority
landfills which closed before 1997 and require regulation
under the 2008 Certification of Historic Unlicenced
Waste Disposal and Recovery Activity Regulationsc.
Number of landfills by type in 2009
MSW (Open)
304 2
12
68
327
Inert (Open)
Mono (Open)
IPPC (Open)
Closed (EPA Licensed)
Closed (Subject toS.I.No. 524 of 2008)
c Waste Management (Certification of Historic Unlicenced Waste Disposal and Recovery Activity) Regulations, 2008 [S.I. No. 524 of 2008].
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Compliance assessment
The regulation of landfills by the EPA has resulted in
significant improvement in landfill operational standards.
By July 2009 (the latest date for compliance with Landfill
Directive requirements), all open MSW landfills were
landfilling in lined cells, collecting leachate, undertaking
extensive environmental monitoring, operating
a weighbridge and maintaining records of waste
accepted. In addition, all open MSW landfills with
the exception of one were flaring/utilising landfill gas.
Standards at open MSW landfills in 1995-1997 versus 2009
Indicator 1995-1997 2009
Number of open MSW landfills
95* 30
%
Records kept of waste accepted
71** 100
Weighbridge operating 10** 100
Landfilling in lined cells 26*** 100
Collecting leachate 33*** 100
Using daily cover 30*** 97****
Flaring/utilising landfill gas 15*** 97****
Monitoring surface water 42* 100
Monitoring groundwater 19* 100
Monitoring leachate 29* 100
Monitoring landfill gas 7* 100
*Based on a survey of standards at 95 local authority
MSW landfills in 1995 and 1996
**Based on a survey of standards at 87 local authority
MSW landfills in 1995
***Based on inspections of 27 local authority MSW
landfills in 1997
****3% ‘non-compliance’ refers to one landfill
Compliance with legislation is assessed by the EPA
through the completion of site inspections and audits
and monitoring of both emissions and the quality
of the environment. Where necessary to secure
compliance, enforcement actions are taken which may
include the issue of notices of non-compliance and
prosecutions. In this regard:
n EPA inspectors conducted 434 audits and
inspections and 147 monitoring visits to sample
surface water, groundwater and leachate and 44
landfill gas monitoring visits in 2008/2009.
n The EPA took 15 successful prosecutions in relation
to landfills during 2001 to 2009 and referred two
cases for prosecution on indictment. Total fines
and costs awarded by the courts amounted to
€250,347.
n Despite the dramatic improvements in operational
standards at landfills, the EPA issued 207
Notifications of Non-Compliance containing 531
individual non-compliances to MSW, inert and
mono landfills in 2008/2009.
Non-compliances issued in relation to MSW, inert & mono landfills in 2008/2009
Leachate & water mgmt.
Landfill gas mgmt.
Lining
Cover/capping/restoration
Odour
Monitoring
Other
69
43
11
60
8894
166
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Outcomes
Regulation of landfills and enforcement of licence
conditions and waste legislation, coupled with
consolidation of the landfill sector has led to positive
environmental outcomes. These outcomes include:
n In excess of 150 hectares of lining was installed in
MSW landfills up to the end of 2008.
n Approximately 1.4 million cubic metres of MSW
leachate was collected and treated in 2008
protecting ground and surface waters.
n Final capping was in place over approximately 61%
of the area of open MSW landfills in 2008 with
temporary capping in place over a further 30%
of this area.
n There has been a significant increase in the use
and flaring of landfill gas resulting in a reduction
of 20% in greenhouse gas emissions from the
landfill sector between 1990 and 2008.
Review of landfill licences
The EPA is currently completing a review of landfill
licences to address the requirement under the Landfill
Directive to reduce landfilling of biodegradable
municipal waste (BMW) to 75%, 50% and 35%
of 1995 levels by 16/07/2010, 16/07/2013 and
16/07/2016 respectively. Landfill of BMW in 2008 was
found to be 280,000 tonnes over the 2010 Landfill
Directive limit. The reviews are also addressing odour
management issues identified as part of EPA audits.
The EPA has completed reviews of 25 licences to-date.
Conclusions & future priorities
The EPA has identified seven priorities for the landfill
sector. These are:
n Diversion of BMW
Almost 1.2 million tonnes of BMW were landfilled
in 2008. In line with EU Directive requirements this
needs to reduce to 0.916 million tonnes in 2010,
0.610 million tonnes in 2013 and 0.427 million
tonnes in 2016.
Increased diversion will require that landfill
operators gain an understanding of and control
the BMW content of waste accepted to landfill,
the provision of capacity for treatment of BMW
and priority enforcement by Regulators.
n Landfill gas
Landfill gas is a source of greenhouse gas
(methane) and poses other environmental risks
if not managed properly. Landfill operators must
ensure that landfill gas is collected and used to
produce energy or flared and avoid causing harm
or nuisance off-site. In this regard, there appears
to be greater scope to use landfill gas to produce
energy and operators should pursue this.
Landfill gas is also odorous and accounted for 71%
of all complaints in relation to licensed facilities in
2009. Landfill operators should implement odour
management plans to provide for comprehensive
control of odour. The EPA has engaged in
significant enforcement in relation to this issue and
will continue to prioritise it.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
n Legacy landfills
There are over 300 local authority landfills that
operated between 1977 and 1997 without
specific authorisation. These landfills must now
be controlled and managed under the Historic
Unlicensed Waste Disposal and Recovery Activity
Regulations to ensure there is no environmental
impact.
n Environmental liabilities & financial provision
Significant financial provision is required to fund
future closure, restoration and aftercare costs at
landfills which continue to pose an environmental
risk after closure. This challenge becomes even
greater against a backdrop of declining revenues
at landfills in recent years. Landfill operators must
ensure that plans and financial provision are in
place for closure/aftercare.
n Cover & capping
Cover and capping of landfilled waste are critical to
the successful prevention of nuisance and control
of landfill gas and leachate. Although cover was
applied at all landfills in 2008, EPA surveys have
found that it was applied correctly in only 50%
of cases and operators need to address this in
accordance with EPA guidance.
n Leachate management
Landfill leachate poses an environmental risk
to ground and surface water if not properly
controlled. The licensing of urban wastewater
treatment plants by the EPA may limit leachate
treatment capacity at urban wastewater treatment
plants and landfill operators need to be aware of
and plan for this.
The EPA has observed reoccurring failures to
maintain leachate levels less than the maximum
1m above the base of landfills and landfill
operators must take measures to strictly comply
with this requirement.
n Waste acceptance
Robust waste acceptance procedures are required
to ensure that waste is disposed of in the
correct class of landfill (inert, non-hazardous or
hazardous). Gypsum waste, for example, deposited
with organic waste can break down into hydrogen
sulphide gas, which is colourless, odorous, toxic
and flammable. The waste sector needs to take
measures to prevent disposal of gypsum waste
with organic waste.
Significant measures are already in place to address
some of the priorities identified above. Chapter 11
of this report sets out the overall actions necessary
and those responsible for implementation. Future
EPA reports will assess the progress or otherwise of
implementing these actions and in addressing the
priorities.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
1. INTRODUCTION
1.1 Background
This report presents a review of landfilling in Ireland and
documents the progress made since the Environmental
Protection Agency (EPA) began regulating landfills in
the mid-1990s. Its scope includes landfills licensed by
the EPA under both the waste and integrated pollution
prevention and control (IPPC) licensing systems and
legacy landfills which under recent legislation will come
under the regulation of the EPA.
The focus of this report is on compliance with the
Landfill Directive1 and the minimum standards for
landfilling it imposes on EU Member States. The
Landfill Directive came into effect on 16/07/2001 and
all landfills were required to comply with its general
technical requirements by 16/07/2009 at the latest. In
addition, the first Landfill Directive target for diversion
of biodegradable municipal waste applies from
16/07/2010 for Ireland.
This report is based on information provided by landfill
operators in their Annual Environmental Reports
(AERs) to the EPA, in responses to questionnaires
and on the experience of the EPA in licensing and
enforcing landfills over the past 15 years. It covers all
environmental aspects of landfilling including: waste
acceptance; infrastructure; monitoring; financial
provision; and closure and aftercare.
1.2 Legal and regulatory framework
The 1975 Waste Framework Directive2 required EU
Member States to establish a permitting system for the
recovery or disposal of waste. This was implemented
in Ireland by the European Communities (Waste)
Regulations, 1979 but was restricted to private sector
waste activities which were required to obtain a permit
from the Local Authorities. This remained the situation
until the Environmental Protection Agency Act, 1992
established the EPA. In 1994, the EPA commenced
integrated pollution control (IPC) licensing and any
landfills associated with IPC activities became regulated
by an IPC licence, e.g. landfills for disposal of ash from
power plants. The Waste Management Act, 1996
introduced licensing by the EPA of stand-alone landfills
from 1997 onwards. From that point, all landfills
required an EPA licence. The EPA Act also required the
EPA to specify criteria for landfill sites and these were
published as follows:
n 1995–Investigations for landfills3
n 1995 updated 2003–Landfill monitoring4,5
n 1997–Landfill operational practices6
n 1999–Landfill restoration and aftercare7
n 2000–Landfill site design8
The Landfill Directive1 was the next major development
in landfill regulation at EU level; it was published on
the 16/07/1999 and Member States were required to
bring it into force by 16/07/2001. Its overall objective
is to prevent or reduce any negative effects on the
environment or human health that are associated
with the landfilling of waste. It specifies technical
requirements for landfill design, operation and closure
and sets deadlines for the diversion of biodegradable
municipal waste from landfill. It was supplemented by
Council Decision 2003/33/EC9 which specifies detailed
criteria for acceptance of waste at landfill.9 The Landfill
Directive and Council Decision are implemented
in Ireland by the Waste Management (Licensing)
Regulations, 2004.
There have been a number of other recent legislative
developments that are important to the regulation of
landfills:
n The Waste Management (Management of Waste
from the Extractive Industries) Regulations, 2009
[S.I. No. 566 of 2009] transpose the requirements
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
of the Extractive Waste Directive10 in Ireland. Waste
that falls under this legislation (e.g. mine tailings
waste) is not subject to the Landfill Directive.
n The Waste Management (Certification of Historic
Unlicenced Waste Disposal and Recovery Activity)
Regulations, 2008 provide for the regulation of
local authority landfills that operated without
specific authorisation between 15/07/1977 and
27/03/1997.
n The European Communities (Environmental
Liability) Regulations, 2008 transpose the
Environmental Liability Directive11 in Ireland and
cover environmental liability in relation to the
prevention and remedying of environmental
damage.
Further detail on the legal and regulatory framework is
provided in Appendix 1.
Figure 1.1Waste disposal at landfill in 2009
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
2. OVERVIEW OF LANDFILLING IN IRELAND
2.1 Number & types of landfill
There has been a dramatic change in landfilling in Ireland
over the last 25 years and in particular since licensing
of landfills commenced in mid-1990s. The number of
open landfills has decreased from over 200 in the mid-
1980s to 48 in 2009 (Figure 2.1). While this trend was
evident before 1997, the introduction of Environmental
Protection Agency (EPA) waste licensing in 1997 and
the associated requirement for higher standards of
design and operation made the operation of many
landfills, especially smaller scale landfills, unfeasible.
Approximately 45 local authority landfills closed around
the time the EPA waste licensing regime came into
force. In addition, a number which applied to the EPA
for licences were licensed for closure and aftercare
only, e.g. Belturbet Landfill and Bailieborough Landfill.
Regulation of closed landfills has become an increasingly
significant issue. The number of closed landfills covered
by EPA licences or requiring regulation under the Waste
Management (Certification of Historic Unlicenced
Waste Disposal and Recovery Activity) Regulations,
2008 [S.I. No. 524 of 2008] is approximately 10 times
the number of open landfills (Figure 2.2).
Figure 2.2Number of landfills by type in 2009
MSW (Open)
304 2
12
68
327
Inert (Open)
Mono (Open)
IPPC (Open)
Closed (EPA Licensed)
Closed (Subject toS.I.No. 524 of 2008)
0
50
100
150
200
250
2009
2008
2007
2006
2005
2004
2003
2002
2001
1998
1995
1985
1994Commencement
of IPC/IPPC licensing
Num
ber
of la
ndfil
ls
1997Commencement of waste licensing
Figure 2.1Numbers of open landfills – 1985 to 2009 (Based on information from an An Foras Forbartha 1985 national waste database report12, an EPA survey of local authority landfills in Ireland from 1995-199713, the EPA national waste database reports for the years 199514, 199815 and 2001 to 200816-23 and from information gathered from landfill operators in 2009 for the purposes of this report.)
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Open landfills
Ireland remains very reliant on landfill for the disposal of municipal waste as is evident from the rate of landfill of municipal waste in 2008 (62.5%)23 which is well above the EU average (42% in 2007).24 There were 30 municipal solid waste (MSW) landfills open during 2009 (Cork City Council, Kinsale Road Landfill closed in mid-2009 leaving 29 open MSW landfills at the end of 2009). This reduction in the number of MSW landfills and the consolidation of the sector into fewer predominantly large-scale landfills mirrors experience in other European Member States24 and is also consistent with government policy to reduce the number of MSW landfills to 20.25 Although the number of private MSW landfills open in 2009 (6) was small relative to the number of local authority MSW landfills (24), the private MSW landfills account for approximately one third of the sector in terms of licensed capacity and waste landfilled.
There were four open inert landfills in Ireland in 2009. These provide for disposal of mainly construction and demolition wastes. However, the majority of this waste stream is recovered at landfills (e.g. used in capping or other engineering works at MSW landfills) or local authority permitted sites. Of the 13.5 million tonnes of C&D waste reported in 2008, only 0.22 million tonnes (2%) was reported as being disposed of at inert landfill.23 The other types of landfills in Ireland are mono landfills (2 open in 2009) and integrated pollution prevention and control (IPPC) landfills (12 open in 2009). One of the IPPC landfills (Gypsum Industries Limited) closed in mid-2009.
Figure 2.3 lists and shows the location of open landfills in Ireland in 2009 with further information given in Appendix 2.
EPA licensed closed landfills
Figure 2.4 lists and shows the location of closed landfills covered by EPA licences in 2009 with further information given in Appendix 2. It should be noted that a number of these landfills were closed before the EPA waste licensing system but came into the waste licensing system because other waste licensable activities (e.g. waste transfer stations) were located at these sites. The number of closed landfills covered by
EPA licences represents only part of the closed landfill ‘sector’. Other categories of closed landfills include:
n Closed landfills falling under the Waste Management (Certification of Historic Unlicenced Waste Disposal and Recovery Activity) Regulations, 2008 [S.I. No. 524 of 2008] (see Section 2.3 and Figure 2.2); and
n Landfills that closed prior to the European Communities (Waste) Regulations, 1979 and private landfills that operated solely under the European Communities (Waste) Regulations, 1979 (these latter two categories are not covered by this report).
An integrated pollution control (IPC) licence for the initial melting or production of iron or steel was granted by the EPA to Irish Ispat Limited on the 02/06/2001. The licence contained conditions dealing with a large-scale on-site landfill. The company went into liquidation and the Liquidator applied to the High Court to disclaim the licence as onerous property. The application was successful and responsibility for the site reverted to the State. An environmental risk assessment has been completed for the landfill. An Office of Public Works working group established by the Government is considering options for the future use of the site, the determination of which will inform the extent and nature of the remediation required.
In addition, the EPA has licensed the remediation/restoration of three illegal landfills in County Wicklow. These licences require the segregation of inert wastes from other wastes. Non-inert waste is required to be sent off-site to waste facilities agreed with the EPA and inert waste is to be used for on-site restoration works. The relevant sites are:
n Swalcliffe Ltd (Licence No: W0181-01)
n Brownfield Restoration Ireland Ltd (Licence No: W0204-01)
n Roadstone Dublin Remediation Landfill (Licence No: W0213-01)
Two of these sites (Swalcliffe Ltd and Roadstone Dublin Remediation Landfill) have been remediated. The other site (Brownfield Restoration Ireland Ltd) is the subject of a High Court case.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
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Licence Reg. No.
Name of FacilityLicence Reg. No.
Name of FacilityLicence Reg. No.
Name of Facility
P0027-02 Medite Europe Limited W0021-02 Derrinumera Landfill Facility W0077-03 Corranure LandfillP0029-02 Irish Cement Limited (Limerick) W0024-04 Ballynacarrick Landfill Site W0078-03 Ballaghveny LandfillP0030-03 Irish Cement Limited (Drogeda) W0025-03 Powerstown Landfill Site W0081-03 KTK Landfill LimitedP0376-01 Premier Periclase Limited W0026-03 Kyletalesha Landfill W0089-02 Derryconnell LandfillP0393-02 Kerry Ingredients (Ireland) Limited W0028-03 Ballydonagh Landfill W0109-02 Central Waste Management FacilityP0419-01 Conoco Philips Bantry Bay Terminals Limited W0029-03 Derryclure Landfill W0129-02 Murphy Environmental Hollywood LimitedP0499-01 Bord na Móna Fuels Limited, Littleton W0030-02 Dunmore Landfill W0146-02 Knockharley LandfillP0519-02 Gypsum Industries Limited* W0037-01 Tradaree Point E.T.P. W0151-01 Murphy Concrete Manufacturing LtdP0605-02 Electricity Supply Board (Moneypoint)** W0047-02 Kerdiffstown W0156-01 KTK Sand & Gravel LtdP0610-01 Electricity Supply Board (Lough Ree Power) W0048-01 Kilmurry South W0165-02 Ballynagran Residual LandfillP0611-01 Electricity Supply Board (West Offaly Power) W0049-02 Clonbulloge Ash Repository W0178-02 East Galway Residual Landfill SiteW0001-04 North Kerry Landfill W0059-03 Ballaghaderreen Landfill W0191-02 Holmestown Waste Management Facility W0004-04 Arthurstown Landfill W0060-03 Whiteriver Landfill Site W0201-03 Drehid Waste Management FacilityW0009-03 Balleally Landfill W0066-03 Rampere Landfill
*Ceased disposal of waste during 2009 **Two open landfills on-site in 2009
W0012-02 Kinsale Road Landfill* W0067-02 Rathroeen LandfillW0017-04 Gortadroma Landfill Site W0068-03 Youghal LandfillW0020-02 Scotch Corner Landfill W0074-03 Donohill Landfill
Figure 2.3 Open landfills in 2009 (See Appendix 2 for further details).
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
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P0012-04 Roche Ireland Limited W0022-01 East Cork Landfill Site W0084-01 AghfarrellP0022-02 Finsa Forest Products Limited W0023-01 Raffeen Landfill Site W0086-01 Kenmare Transfer StationP0031-02 Holfield Plastics Ltd* W0027-02 Pollboy Landfill Facility W0087-01 Cahirciveen Transfer StationP0081-02 Irish Asphalt Limited W0031-01 Doora Landfill Site W0088-01 CorballyP0222-01 Irish Sugar plc (Carlow)** W0032-02 Dungarvan Waste Disposal Site W0090-01 Balbane Landfill SiteP0223-01 Irish Sugar plc (Cork)*** W0033-01 Drogheda Landfill Site W0091-01 Bailieborough LandfillP0225-01 John Ronan & Sons W0034-02 Dundalk Landfill & Civic Waste Facility W0092-01 Belturbet LandfillP0389-01 Thornbrush Holdings Limited W0046-01 Ballylinan Landfill Site W0093-01 Ballyjamesduff LandfillP0498-01 Irish Ispat Limited W0053-03 Greenstar Limited W0125-01 Glenalla Landfill SiteP0516-01 Tara Mines Limited W0062-01 Churchtown Landfill W0126-01 Muckish Landfill SiteP0626-01 Electricity Supply Board (Shannonbridge) W0063-01 Drumabodan Landfill Site W0127-01 Dunsink LandfillP0627-01 Electricity Supply Board (Bellacorick) W0064-01 Carrick-on-Shannon Landfill W0139-01 Haroldstown Transfer StationP0629-01 Electricity Supply Board (Lanesborough) W0065-01 Mohill Landfill W0170-01 Lisdeen Recycling Centre & Transfer StationW0002-02 Ballyguyroe Landfill Site W0069-01 Milltown Transfer Station W0181-01 Swalcliffe LtdW0010-02 Basketstown Landfill Facility W0070-01 Benduff Landfill Site W0199-01 Srahmore Peat Deposition SiteW0011-01 Ballymurtagh Landfill Facility W0071-02 Marlinstown Landfill W0204-01 Brownfield Restoration Ireland LimitedW0013-01 Carrowbrowne Landfill Site W0072-01 Coolcaslagh Transfer Station W0213-01 Roadstone Dublin Remediation LandfillW0014-01 Silliot Hill Landfill W0073-01 Roscommon.Landfill Facility
*There are four closed landfills on this site**There are two closed landfills on this site***There are six closed landfills on this site
W0015-01 Ballyogan Landfill Facility & Recycling park W0075-02 Tramore Waste Disposal SiteW0016-02 Killurin Landfill Site W0076-01 LongpavementW0018-01 Kilbarry Landfill Site W0080-01 Dillonsdown
Figure 2.4 EPA licensed closed landfills in 2009 (See Appendix 2 for further details).
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Future trends
The number of open landfills is expected to decline
further in the short-term due to the closure of existing
landfills that are near capacity and the lack of new
projects coming on-line. In the MSW landfill sector, the
rate of application for licences has slowed considerably,
particularly in relation to new developments. The
licence recently granted to Fingal County Council for
the proposed landfill at Nevitt, Lusk, Co. Dublin was
the first licence for a new MSW landfill granted by
the EPA since 2006. The remaining fully consented
MSW landfill capacity (i.e. with waste licence and
planning permission in place) was approximately
24 million tonnes nationally at the end of 2008.23
If disposal to MSW landfill continues at the 2008
rate of approximately 2 million tonnes per annum,
there is approximately 12 years MSW landfill capacity
remaining, i.e. to 2020. The diversion of biodegradable
municipal waste (BMW) from landfill and other potential
changes in how waste is managed are likely to reduce
the demand for MSW landfill. The future of inert, mono
and IPPC landfilling is difficult to predict. The last inert,
mono and IPPC landfill licences were granted in 2003,
2004 and 2004 respectively and there are two inert
landfill applications currently with the EPA.
2.2 Environmental standards & enforcement
Table 2.1 summarises the change in environmental
standards at MSW landfills since the commencement
of EPA licensing and shows that the licensing of
landfills and the associated implementation of EPA
standards and EU legislation has resulted in a dramatic
improvement in standards overall.
Surveys of standards at MSW landfills in 1995-1996
found that environmental monitoring was carried out at
7% to 42% depending on the environmental medium
(surface water, groundwater, leachate or landfill gas),
records of waste accepted were kept at 71% and a
weighbridge was operated at only 10% of landfills.13,14
Inspections of 27 MSW landfills in 1997 found that
26% were landfilling in lined cells, 33% were collecting
leachate and 15% were flaring/utilising landfill gas.13
By 16th July 2009 (the latest date for compliance with
Landfill Directive requirements), all open MSW landfills
were landfilling in lined cells, collecting leachate,
undertaking extensive environmental monitoring,
operating a weighbridge and maintaining records of
waste accepted. In addition, all open MSW landfills,
except one, were flaring/utilising landfill gas.
Table 2.1
Comparison of standards pertaining at open MSW landfills in 1995-1997 versus 2009
Indicator 1995-1997 2009
Number of open MSW landfills 95* 30
%
Records kept of waste accepted 71** 100
Weighbridge operating 10** 100
Landfilling in lined cells 26*** 100
Collecting leachate 33*** 100
Using daily cover 30*** 97****
Flaring/utilising landfill gas 15*** 97****
Monitoring surface water 42* 100
Monitoring groundwater 19* 100
Monitoring leachate 29* 100
Monitoring landfill gas 7* 100
*Based on a survey of standards at 95 local authority
MSW landfills in 1995 and 199613
**Based on a survey of standards at 87 local authority
MSW landfills in 199514
***Based on inspections of 27 local authority MSW
landfills in 199713
****3% ‘non-compliance’ refers to one landfill
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Environmental Protection Agency
Offi ce of Environmental Enforcement (OEE)
Similar baseline information is not available on which
to assess changing standards at inert, mono and IPPC
landfi lls. However, as with MSW landfi lls, these landfi lls
are now subject to much stricter standards than would
have applied historically. For example, ash landfi lls were
historically unlined, however, any new ash landfi lls
licensed by the EPA (of which there are four since
2000) are required to be lined.
The EPA enforces landfi ll licences through audit,
inspection, monitoring and assessment of reports
submitted by landfi ll operators. EPA inspectors
conducted 333 audits and inspections of MSW, inert and
mono landfi lls in 2008/2009. In addition, EPA Regional
Laboratory personnel carried out 120 monitoring visits
to sample surface water, groundwater and leachate and
44 landfi ll gas monitoring visits. The EPA also deployed
site agents to investigate odour issues at landfi lls and
commissioned external experts to conduct 54 landfi ll
gas management and surface emissions assessments
at landfi lls in 2008/2009. There were 47 audits and
inspections and 27 water monitoring visits to IPPC sites
with landfi lls in 2008/2009. The EPA took 15 successful
prosecutions in relation to landfi lls during 2001 to
2009 and referred two cases to the Director of Public
Prosecutions (DPP) which were successfully prosecuted
on indictment (Table 2.2). These resulted in total fi nes
and costs of €250,347 being imposed by the courts. The
EPA submitted a further three cases to the DPP in 2009.
Figure 2.5Poor environmental management at MSW landfi ll in 1997
Figure 2.6Good environmental management at MSW landfi ll in 2008
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Table 2.2Prosecutions relating to landfills 2001 to 2009
Licensee Landfill Year Fines Costs
South Dublin Co. Co. Arthurstown Landfill 2009 €600 €9,850
Greenstar Recycling Holdings Ltd East Galway Residual Landfill 2009 €3,500 €47,145
Roscommon Co. Co. Ballaghaderreen Landfill 2008 €5,000 €8,300
Cavan Co. Co. Corranure Landfill 2007 €4,500 €21,500
Ballinasloe Town Council Pollboy Landfill Facility 2006 €1,750 €10,104
Waterford City Council* Kilbarry Landfill Site 2006 €6,000 €10,801
Waterford Co. Co.* Tramore Waste Disposal Site 2006 €4,000 €12,719
Cavan Co. Co. Corranure Landfill 2005 €1,900 €6,008
Monaghan Co. Co. Scotch Corner Landfill 2005 €1,600 €7,142
Offaly Co. Co. Derryclure Landfill 2005 €2,500 €5,293
Roscommon Co. Co. Ballaghaderreen Landfill 2005 €2,250 €7,296
Limerick City Council Longpavement 2005 €3,000 €3,152
Dundalk Town Council Dundalk Landfill 2004 €4,800 €4,596
Murphy Concrete Manufacturing Murphy Concrete Manufacturing 2003 €1,200 €11,326
Dun Laoghaire-Rathdown Co. Co. Ballyogan Landfill Facility 2002 €3,200 €9,457
Donegal Co. Co. Muckish Landfill 2002 €2,000 €9,565
Fingal Co. Co. Balleally Landfill 2001 €4,444 €13,849
Total €52,244 €198,103
*Prosecution on indictment.
Leachate & water mgmt.
Landfill gas mgmt.
Lining
Cover/capping/restoration
Odour
Monitoring
Other
69
43
11
60
8894
166
Figure 2.7Non-compliances issued in relation to MSW, inert & mono landfills in 2008/2009
Despite the dramatic improvements in environmental
standards at landfills as detailed above, the EPA is still
detecting non-compliances through its enforcement
activities. The EPA issued 207 Notifications of Non-
Compliance containing 531 individual non-compliances
to MSW, inert and mono landfills in 2008/2009. The
breakdown in terms of non-compliance type is shown in
Figure 2.7 and further analysis is provided in the relevant
chapters. Similar analysis is not possible for IPPC landfills
due to the difficulties in isolating non-compliances
relating to IPPC landfills from non-compliances relating
to the principal IPPC activities on such sites.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
2.3 Legacy landfills
The Waste Management (Certification of Historic
Unlicenced Waste Disposal and Recovery Activity)
Regulations, 2008 [S.I. No. 524 of 2008] require local
authorities to complete the following in relation to
local authority landfills that operated without a waste
licence between 15/07/1977 and 27/03/1997 (referred
to as ‘closed landfills’):
n identify all closed landfills by 30/06/2009
n maintain a register of closed landfills
n carry out a risk assessment of closed landfills under
an EPA Code of Practice26
n apply to the EPA for a certificate of authorisation
for closed landfills
The EPA developed an electronic register of closed
landfills that can be accessed by local authorities via
the internet. There were 327 sites that fall under the
Certification of Historic Unlicenced Waste Disposal and
Recovery Activity Regulations entered in the register at
the end of 2009 (Table 2.3). The website also assists
users in completing Tier 1 of the risk assessment which
consists of desk-based studies and a site walkover.
The boundary of the site is entered in a Geographic
Information System (GIS) tool that automatically
generates a risk classification for the site (Figure 2.8)
using information regarding the local environment
contained in the GIS, e.g. details of surface water
features, groundwater vulnerability and proximity to
protected areas and human presence. The information
must be validated using site-specific information
gathered during a site walkover survey. This risk
classification facilitates the scoping and prioritising
of Tier 2 of the risk assessment which consists of
more detailed on-site intrusive investigations such as
monitoring of waste, emissions, surface water and
groundwater. The Department of the Environment,
Heritage and Local Government (DEHLG) is funding
a pilot project on environmental risk assessment of
historic landfills involving 17 sites (15 local authorities).
Exploratory investigations at these sites were completed
at the end of 2009 and main site investigations were
being commenced. The EPA is providing assistance
by developing decision matrices to ensure site
investigations are carried out to the standards required
under the Code of Practice.
Figure 2.8Electronic register and risk classification for closed landfill
Closed Landfill
Risk Classification:
Class C
Lowest Risk
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Table 2.3Sites entered in the closed sites register (S.I. No. 524 of 2008) at the end of 2009
Local authority No. sites Local authority No. sites Local authority No. sites
Carlow Co. Co. 1 Kildare Co. Co. 19 Offaly Co. Co. 5
Cavan Co. Co. 14 Kilkenny Co. Co. 12 Roscommon Co. Co. 4
Clare Co. Co. 8 Laois Co. Co. 15 Sligo Co. Co. 2
Cork Ci. Co. 5 Leitrim Co. Co. 6 South Dublin Co. Co. 6
Cork Co. Co. 50 Limerick Ci. Co. 1 South Tipp Co. Co. 9
Donegal Co. Co. 24 Limerick Co. Co. 20 Waterford Ci. Co. 3
Dublin Ci. Co. 0 Longford Co. Co. 9 Waterford Co. Co. 2
DLR Co. Co. 0 Louth Co. Co. 4 Westmeath Co. Co. 13
Fingal Co. Co. 4 Mayo Co. Co. 5 Wexford Co. Co. 13
Galway Ci. Co. 1 Meath Co. Co. 7 Wicklow Co. Co. 10
Galway Co. Co. 22 Monaghan Co. Co. 5
Kerry Co. Co. 13 North Tipp Co. Co. 15
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
3. Landfill conditioning plans
Landfill Directive
Article 14 required that existing landfills (i.e. those already operational or licensed on 16/07/2001) be closed
unless the following steps were completed by 16/01/2001:
n The operators were required to submit a landfill conditioning plan by 16/07/2002 which would detail any
corrective measures necessary to comply with the Landfill Directive; and
n The competent authority (EPA) would decide on the basis of the landfill conditioning plan whether the
site could continue to operate and, if so, authorise and specify a period by which the necessary measures
would be taken to comply with the Landfill Directive no later than 16/07/2009; or
n The landfill would be required to close in accordance with Articles 7(g) and 13 of the Landfill Directive.
3.1 Introduction
In order to implement Article 14 of the Landfill
Directive, the Environmental Protection Agency (EPA)
developed landfill conditioning plan guidance and a
template for landfill operators and held a workshop for
landfill operators in 2002 in relation to the preparation
of landfill conditioning plans. The landfill conditioning
plans were submitted by the operators and assessed
in conjunction with any other relevant information
(licences, monitoring results, etc.) by the EPA to check
compliance with the Landfill Directive. The outcome of
the assessment in relation to the various landfill types
is detailed below. It should be noted that many of the
standards which came to be specified in the Landfill
Directive when it came into force in 2001 were already
being specified by the EPA in licences issued before that
time. Any issues identified by the landfill conditioning
plan assessment process are being addressed through
licence reviews to specify any measures necessary to
reinforce compliance with the Landfill Directive.
3.2 MSW landfills
Fifty municipal solid waste (MSW) landfills were
operational on 16/07/2001 and were subject to the
landfill conditioning plan requirement. Twenty-four of
these continued to operate after 16/07/2009 which
is the final deadline for compliance with the Landfill
Directive. While the vast majority of the requirements
of the Landfill Directive were provided for in the
licences for these landfills, the licences are being
reinforced where necessary to:
n Give effect to the Landfill Directive requirements to
divert BMW and treat waste before landfill.
n Upgrade landfill gas management and odour
control conditions.
n Require the setting of groundwater trigger levels.
n Make certain waste acceptance procedures
more explicit, e.g. the checking of waste and
documentation at the entrance, waste testing
requirements, notification of reject loads,
provision of receipts for waste accepted and the
ban on disposal of gypsum waste in cells taking
biodegradable waste.
The other 26 MSW landfills which were subject to the
landfill conditioning plan requirement closed by the
16/07/2009 deadline and, following assessment, the
licences for these landfills were found to be satisfactory
and provide for closure and aftercare in accordance
with the Landfill Directive.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
3.3 Inert, mono & IPPC landfills
Twelve of the open inert, mono and integrated
pollution prevention and control (IPPC) landfills were
operational on 16/07/2001 and were subject to the
landfill conditioning plan requirement. Seven of these
landfills do not have a liner installed (Table 3.1). The
Landfill Directive does allow departure from the lining
standards specified therein where justifiable based on
environmental risk and this issue is being further assessed
as part of the licence review process referred to above.
Table 3.1Unlined inert and IPPC landfills
Landfill Waste type
Kilmurry South
[Marrakesh Limited]
Inert
Electricity Supply Board
(Moneypoint)
Coal ash
Kerry Ingredients (Ireland)
Limited
Coal ash
Premier Periclase Limited Lime dust, spent
refractories and grits
Irish Cement Ltd [Drogheda] Inert
Bord na Mona Fuels Limited
[Littleton]
Peat ash, peat
Conoco Philips Inert
The inert and mono landfills are for the most part
compliant with the Landfill Directive. Amendments
to licences are being undertaken to make waste
acceptance procedures more explicit and require
the setting of groundwater trigger levels. The IPPC
landfill licences also require such amendments and
amendments to address some or all of the following
issues depending on the landfill:
n Landfill classification
n Waste testing
n Monitoring
n Site security
n Landfill stability
The EPA also assessed the landfill conditioning plans
and licences for inert and IPPC landfills which were
subject to the landfill conditioning plan requirement
but which have closed. The licences for these landfills
were found to be satisfactory and provide for closure
and aftercare in accordance with the Landfill Directive.
Figure 3.1IPPC landfill
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4. Treatment of waste and diversion of BMW
Landfill Directive
Article 5 requires that Member States establish a national strategy to reduce the amount of BMW going to
landfills as follows:
n To 75% of the total amount of BMW generated in 1995 by 16/07/2006
n To 50% of 1995 levels by 16/07/2009
n To 35% of 1995 levels by 16/07/2016
Member States which landfilled more than 80% of their MSW in 1995 were allowed a derogation of up to four
years. Ireland availed of this for the first two targets which have been deferred to 16/07/2010 and 16/07/2013
respectively and intends to review whether a derogation is necessary in relation to the 2016 target.27
Article 6(a) specifies that Member States shall take measures in order that:…
…only waste that has been subject to treatment is landfilled. This provision may not apply to inert waste
for which treatment is not technically feasible, nor to any other waste for which such treatment does not
contribute to the objectives of this Directive, as set out in Article 1, by reducing the quantity of the waste
or the hazards to human health or the environment…
4.1 Introduction
Treatment of waste prior to landfill and diversion of
biodegradable municipal waste (BMW) from landfill
are two key elements of EU waste policy. Many waste
streams that can be recovered are ending up in landfill
representing an inefficient use of resources. Landfilling
of BMW results in high emissions of methane which is
a significant greenhouse gas (with a global warming
potential 21 times that of carbon dioxide28) and a
potential source of odour nuisance. The EU Landfill
Directive requires measures to be taken to reduce the
landfill of BMW and encourages the separate collection
of BMW and the sorting, recovery and recycling of this
waste. Articles 5 and 6 of the Landfill Directive set out
Member State obligations in relation to the diversion
of BMW from landfill and treatment of waste prior to
acceptance at landfill. These two separate, yet parallel,
issues are dealt with in the following sections.
4.2 Treatment of waste
Sometimes known as ‘pre-treatment’, treatment
includes but is not limited to the following processes29:
n Source separation (e.g. home composting)
n Separate collections (e.g 2 or 3 bin systems)
n Manual Sorting
n Composting
n Energy recovery
n Rendering
n Mechanical treatment of waste (e.g. crushing,
tromelling, magnetic separation etc)
n Biological stabilisation of residues from mechanical
treatment
n Thermal treatment
n Aerobic/anaerobic digestion
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4.3 Diversion of BMW
The percentage limits for diversion of BMW specified
in the Landfill Directive are shown in actual waste
quantities in Table 4.1 and Figure 4.1. The distance-
to-target or ‘gap’ between the 2008 rate of landfill
of BMW (1,196,044 tonnes) versus the 2010 Landfill
Directive limit (916,000 tonnes) is 280,000 tonnes.
The Environmental Protection Agency (EPA) funded
ISus model predicts further reductions in municipal
waste generation, which has been declining since
2007, until 2011/2012 which will assist in meeting the
Landfill Directive target for 2010.23 However, assuming
an economic recovery in 2011 and beyond, the ISus
model predicts that the volume of municipal waste will
increase by 3 to 4% per annum which will increase the
challenge in meeting the 2013 and 2016 targets for
diversion of BMW from landfill.23
Figure 4.1BMW landfilled versus Landfill Directive % limits converted to tonnage limits23
0
200,000
40,0000
600,000
800,000
1,000,000
1,200,000
1,400,000
1,600,000
2017 20182016201520142013201220112010200920082007200620052004
–––– BMW Landfilled
–––– 2010 – 2012 Target
–––– 2013 – 2015 Target
–––– 2016 Onwards Target
Ton
nes
Table 4.1BMW baseline, quantities landfilled, Landfill Directive % limits and converted to tonnage limits23
BMW generation – 1995 baseline
1995 Quantity generated
(tonnes)
1,220,840
BMW landfilled – current position
Quantity landfilled
(tonnes)
2004 1,218,159
2005 1,221,483
2006 1,324,700
2007 1,342,646
2008 1,196,044
BMW Landfill Directive obligations
Landfill Directive
obligations
Maximum quantity
allowed to be
landfilled (tonnes)
2010 75% of quantity
generated in 1995
916,000
2013 50% of quantity
generated in 1995
610,000
2016 35% of quantity
generated in 1995
427,000
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In 2008, the EPA published Hitting the Targets
for Biodegradable Municipal Waste: Ten Options
for Change. It proposed ten possible public policy
interventions to encourage changes in management
practices for biodegradable wastes.30
In 2009, the EPA published Municipal Solid Waste – Pre-
Treatment & Residuals Management.29 This document
set-out the EPA position in relation to the Landfill
Directive treatment and BMW diversion requirements
and the EPA plan to review waste licences for operational
landfills accepting municipal waste. It set out what
waste treatment obligations will apply at landfill
facilities and indicated that diversion of BMW will have
to be demonstrated by individual landfill facilities. The
EPA proposed that the Landfill Directive obligations for
diversion of BMW be translated into a maximum BMW
content allowed in MSW disposed of to individual
landfills. Based on latest waste data, it is considered
necessary to limit the amount of BMW accepted at
landfills to 47% of MSW in order to meet the 2010
Landfill Directive target.31 The EPA has also specified a
stabilisation standard for waste:
‘stabilisation’ means the reduction of the
decomposition properties of biowaste to such an
extent that offensive odours are minimised and
that the Respiration Activity after four days (AT4) is
<10mg O2/g DM (until 1-1-2015), and <7mg O2/g
DM thereafter.
Waste which is stabilised in accordance with the above
standard will not be considered BMW when determining
the quantity of BMW disposed of to landfill.
4.4 Implementation of waste treatment & BMW diversion
The EPA has developed a waste characterisation
protocol for calculating BMW content in municipal
waste consigned for disposal at landfill. The protocol
was issued for public consultation on 25/11/200932:
http://www.epa.ie/downloads/advice/waste/
municipalwaste/name,27244,en.html
The EPA also commenced a sampling/analysis campaign
in December 2009 which is characterising the outputs
to landfill from pre-treatment facilities in order to
identify the BMW content in these waste streams.
This work is ongoing in 2010 with 25 pre-treatment
facilities visited by end of April 2010.
The EPA held a landfill conference in October 2009
focusing on the diversion of BMW. Presentations by
EPA speakers are available as video broadcasts on the
EPA website:
http://www.epa.ie/downloads/videos/
wasteworkshop/#d.en.28003
Review of landfill licences to implement waste
treatment and diversion of BMW requirements
commenced in June 2009 focusing on open MSW
landfills that were predicted to remain open after
the 2010 deadline for diversion of BMW. Twenty-five
of these MSW landfill licences were reviewed and
issued by end of March 2010. Enforcement of these
requirements will present a major challenge and
will require significant work in the development of
guidance for operators and the implementation of
additional waste characterisation and recording. Full
participation of all stakeholders in the waste sector will
be required to meet the Landfill Directive targets.
The Waste Management (Food Waste) Regulations,
2009 came into operation on 01/01/2010 with the
main provisions having effect from 01/07/2010. The
Regulations are designed to promote the segregation
and recovery of food waste arising in the commercial
sector to facilitate the achievement of the targets set out
in the Landfill Directive for the diversion of BMW from
landfill to composting and other forms of authorised
treatment. The Regulations impose obligations on the
major sources of food waste, such as State buildings
where food is prepared, restaurants and cafés, hot
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food outlets, canteens, hotels and larger guest houses,
supermarkets and other food retailers, to segregate these
materials and make them available for separate collection.
Alternatively, these materials can be treated on the
premises where they arise under specified conditions.
The Minister for Environment, Heritage and Local
Government issued Circular WPRR 17/08 to all City
and County Managers in July 2008.33 The circular letter
requested local authorities to accelerate the roll-out
of “brown bin” source-segregated collection systems
for organic waste in order to drive the diversion of
BMW from landfill. Annual Implementation Reports
are required and the circular points to the need to
ensure that the Waste Management Plans are used to
implement biowaste measures.
In addition to the above, there are a number of
priority actions identified in the 2008 National Waste
Report that are necessary for improvements in BMW
management in Ireland.23 These are:
n Continue to promote food waste prevention
through the National Waste Prevention Programme
n Put in place services for the separate collection of
organic (particularly food) waste at household and
commercial premises
n Ensure there is adequate infrastructure to treat the
very large quantities of organic (particularly food)
waste that must be diverted from landfill
n Develop outlets for the products of such treatment
n Make regulations/bye-laws that can be used to
enforce the segregation and separate collection of
food waste at household and commercial premises
n Deliver new waste policy on foot of the
International Review of Waste Management
Policy in Ireland as quickly as possible to provide
certainty and to allow for accelerated investment
programmes that are necessary if organic waste is
to be treated and landfill avoided
Future National Waste reports will track how Ireland
meets these challenges and the Landfill Directive targets.
Figure 4.2Overview of Waste Transfer Station
Figure 4.3Treatment of waste – separation of cardboard and metal
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Figure 4.4Compost facility for treatment of waste
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5. Waste Acceptance
Landfill DirectiveArticle 5(3) bans the following wastes from landfill:
n Liquid waste
n Waste which is explosive, corrosive, oxidising, highly flammable or flammable in the conditions of a landfill
n Hospital and other clinical wastes which are infectious
n Whole used tyres and shredded tyres (excluding tyres used as engineering material, bicycle tyres and
tyres with an outside diameter above 1,400mm)
Article 6(b),(c) & (d) specify that:
n Landfills for non-hazardous waste can only be used for:
• municipal waste
• non-hazardous waste which fulfils the waste acceptance criteria
• stable, non-reactive hazardous waste (in separate cells to biodegradable non-hazardous waste)
n Landfills for inert waste can only be used for inert waste
Article 11 requires that landfill waste acceptance procedures must include the following:
n Demonstration by means of documentation that the waste can be accepted
n Checking of waste documentation
n Visual inspection of the waste at the entrance and point of deposit
n The keeping of samples and sample results
n The keeping of a register of the wastes deposited
n Provision of written receipt of each delivery
n The notification to the competent authority of non-acceptance of waste
Annex II specifies general principles and procedures for characterisation and acceptance of waste at each
class of landfill: inert, non-hazardous and hazardous.
Council Decision 2003/33/ECCouncil Decision 2003/33/EC expands on Annex II of the Landfill Directive and its requirements include:
n Basic characterisation and compliance testing except for:
• Certain inert waste streams for disposal in inert landfill (e.g. concrete, bricks)
• Municipal waste for disposal in non-hazardous landfill
n Compliance with the limit values specified for the various classes of landfill
n Testing by independent and qualified persons in accordance with European Committee for
Standardisation (CEN) standards or national standards
n Restrictions on disposal of non-hazardous gypsum-based materials and construction materials
containing asbestos
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5.1 Introduction
The Landfill Directive classifies landfills as inert,
non-hazardous or hazardous and specifies technical
requirements accordingly.1 For example, the lining
systems required for non-hazardous landfills are of a
much higher specification as compared to inert landfills
and are of a higher specification again for hazardous
landfills. It is therefore important that proper waste
acceptance procedures are in place to ensure that
waste is disposed of in the correct class of landfill.
Controls are also necessary to ensure waste is correctly
characterised, inspected and documented.
5.2 Pre-EPA licensing
Prior to EPA licensing, waste acceptance procedures
at landfills were poor. An EPA survey of local authority
operated municipal solid waste (MSW) landfills in 1995
found that 10% had a weighbridge and 71% kept
records of the quantity and type of waste accepted.14
5.3 Implementation of waste acceptance requirements
Licence requirements
Environmental Protection Agency (EPA) licences for MSW
landfills require waste characterisation and acceptance
procedures. The following are explicit requirements:
n The categories (e.g. household, commercial) and
quantities of waste that can be accepted
n The prohibitions regarding hazardous waste, liquid
waste and waste tyres
n The operation of a weighbridge, waste inspection
area and waste quarantine area
n The inspection of waste and associated documentation
n The maintenance of records of waste accepted
and rejected
Detailed testing requirements are agreed through the
waste acceptance procedures conditioned in each
licence. MSW licences are currently under review by
the EPA. The reviewed licences will bring greater clarity
in relation to waste acceptance. For example, the
requirement to check waste at the entrance (as well as
at the working face), check waste documentation and
the ban on gypsum waste will be made explicit in the
reviewed MSW licences.
Inert landfills are limited to the acceptance of inert waste
and detailed acceptance criteria are specified in Council
Decision 2003/33/EC. The mono and integrated
pollution prevention and control (IPPC) landfills only
accept a very limited number of waste types from single
activities usually located on the same site. The majority
are for ash from power plants. Waste acceptance
criteria are specified accordingly.
Enforcement
The EPA enforces waste acceptance requirements
during the audits and inspections conducted by its
inspectors and through the auditing of waste records
maintained at the landfills and submitted to the EPA
in Annual Environmental Reports. The EPA also cross
checks records held at facilities consigning waste to
landfill. The EPA issued 20 non-compliances relating
to waste acceptance in 2008/2009. Common issues
identified were:
n Failure to inspect waste adequately at the working
face
n Acceptance of unsuitable waste types
n Acceptance of waste outside of authorised hours
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The EPA facilitated visits by the European Commission
to three MSW landfills in early 2009 to examine waste
acceptance procedures. This was part of a wider
European Commission survey of waste acceptance across
the EU. The final report34 is available on the EU website:
http://ec.europa.eu/environment/waste/landfill_
index.htm
5.4 Specific waste acceptance issues
Gypsum waste
Gypsum waste co-disposed with organic waste can
break down into hydrogen sulphide (H2S) gas, which is
colourless, toxic and flammable and can lead to odour
nuisance. Council Decision 2003/33/EC prohibits the
disposal of non-hazardous gypsum-based materials in
landfills for non-hazardous waste unless in cells where
no biodegradable waste is accepted.9 This essentially
amounts to a ban on the landfilling of gypsum waste
in Ireland at present as none of the MSW landfills has
a separate cell for gypsum waste and disposal to inert
landfill is not acceptable. Recycling facilities for gypsum
waste are available in Ireland. In 2007/2008, the EPA
issued a circular letter to EPA licensed waste operators
informing them of these legal requirements and advising
that gypsum wastes should be segregated from other
construction and demolition (C&D) waste and sent to
authorised gypsum recycling facilities. The EPA also wrote
to local authority waste regulators to ensure compliance
at local authority regulated sites and asked the
Construction Industry Federation (CIF) and the National
Construction and Demolition Waste Council (NCDWC)
to bring the matter to the attention of the C&D sector.
In 2009, the EPA piloted a test method for measuring
gypsum content in C&D fines at two EPA licensed transfer
stations. As a result, one of the sites was required to
examine its waste handling procedures to ensure effective
gypsum waste separation. Enforcement in this area will
continue. Compliance with the gypsum ban was raised
at a meeting of the EU Landfill Directive Committee*
on 13/11/2009 and the European Commission are to
follow-up further in relation to this issue.
Asbestos
The Landfill Directive permits the landfill of stabilised
non-reactive hazardous waste in non-hazardous landfill in
separate cells to biodegradable waste.1 Council Decision
2003/33/EC expands on this in relation to construction
material containing asbestos (EWC 17 06 05*) and
other suitable asbestos waste which are allowed to be
landfilled in separate cells in non-hazardous landfills
subject to a strict set of criteria.9 These include: the
asbestos must be covered daily, no works can be carried
out that could release fibres (e.g. drilling of holes), the
location of the cell must be recorded, afteruse must be
limited to avoid human contact, etc..
There is currently no non-hazardous landfill in Ireland
with a separate cell for asbestos waste. Nor is there
a general hazardous waste landfill. The National
Hazardous Waste Management Plan 2008-2012 raised
concerns that the resultant export costs associated with
disposal of asbestos encourages illegal disposal and
identified a required landfill capacity of 20,000 tonnes
per annum for asbestos waste.35 The Plan recommends
that at least one national hazardous waste landfill be
developed in Ireland with a capacity of at least 15,000
tonnes per annum for asbestos and that at least one
non-hazardous landfill be authorised to accept 5,000
tonnes per annum of asbestos (in a separate cell as
provided for under the Landfill Directive). A reviewed
waste licence was granted in respect of Greenstar
Holdings Limited, East Galway Residual Landfill Site,
on 23/03/2010 which provides for the landfilling in a
separate cell of 3,000 tonnes per annum of asbestos.
Hazardous waste landfill capacity
The deficiency in landfill capacity for hazardous waste
has been raised in successive National Hazardous Waste
Management Plans35,36 In addition to the requirements
for landfill capacity for asbestos waste (see above),
the 2008-2012 plan identifies a required hazardous * Committee for the Adaptation to Scientific and Technical Progress
- Directive 1999/33/EC on the Landfill of Waste
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landfill capacity of 10,000 tonnes per annum for
other hazardous wastes such as industrial waste
and contaminated soil and recommends that this be
provided at a national hazardous waste landfill.35 The
Plan recommends that the EPA commission a study to
clarify the technical and economic aspects of providing
hazardous waste landfill capacity. This study was
completed in June 2010.
Waste acceptance matters to be decided by Member States under Council Decision 2003/33/EC
While Council Decision 2003/33/EC is a relatively explicit
and detailed technical document, a number of matters
are to be decided by Member States.9 The EPA has
approached these issues on a case-by-case as they arise.
A significant issue left to Member States was to specify
the limit value for polycyclic aromatic hydrocarbons
(PAHs) in waste accepted for disposal in landfills for inert
waste. The EPA currently specifies a limit of 100mg/
kg for a suite of 17 PAHs.37 In addition, in the absence
of limits for disposal to general non-hazardous landfill,
the EPA specifies that the levels of PAH must be such
that they (in combination with any other contaminants
present) do not render the waste hazardous.
The EPA has also specified the procedure that must be
followed in relation to application of higher limit values
(Council Decision 2003/33/EC allows limit values to be
exceed by up to three times in certain circumstances)
and requires that the landfill operator:
n Make an application in writing to the EPA
n Detail the reasons for the application
n Provide a risk assessment of the impact of the
waste in question
The EPA will only authorise the application of higher
limit values on a case-by-case basis, where there is
good reason and emissions will present no additional
environmental risk.
Finally, Council Decision 2003/33/EC specifies limit
values for granular waste but not for monolithic
waste.9 Member States were to set criteria for
monolithic waste to provide the same level of
environmental protection as the limit values for
granular waste. Ireland has not specified specific
criteria for monolithic waste. This issue was addressed
at a meeting of the EU Landfill Directive Committee
on 13/11/2009 where it was recognised that this is
a very complex area and there is variance in how it is
being implemented across the EU Member States. The
Committee has now established a sub-Committee to
develop criteria for monolithic waste at EU level.
5.5 Guidance & standards
The correct classification of waste and the identification
of whether it is hazardous or not is a prerequisite
to decide whether it is acceptable for disposal in a
particular class of landfill. The following guidance can
be used to determine same:
European Waste Catalogue and Hazardous Waste
List – Valid From 1 January 200238
Procedure for the Identification of the Hazardous
Components of Waste & Hazardous Waste
Classification Worksheet 39
The EPA intends to develop further guidance in relation
to waste acceptance in 2010.
Finalised European Committee for Standardization
(CEN) documents relating to the sampling and testing
of waste are available through the National Standards
Authority of Ireland (NSAI):
http://www.nsai.ie/
Details of draft European Standards can be found on
the CEN website:
http://www.cen.eu/cenorm/homepage.htm
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Figure 5.1Landfill entrance including weighbridge
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6. Landfill lining & leachate management
Landfill Directive
Annex I requires that:
… Protection of soil, groundwater and surface water is to be achieved by the combination of a geological
barrier and a bottom liner…
The landfill base and sides shall consist of a mineral layer…at least equivalent to…the following:
n Landfill for hazardous waste: permeability ≤ 1 x 10-9 m/s; thickness ≥5m
n Landfill for non-hazardous waste: permeability ≤ 1 x 10-9 m/s; thickness ≥1m
n Landfill for inert waste: permeability ≤ 1 x 10-7 m/s; thickness ≥ 1m
Where the geological barrier does not naturally meet the above conditions it can be completed artificially…
giving equivalent protection. An artificially established geological barrier should be no less than 0.5 metres thick.
In addition to the geological barrier described above a leachate collection and sealing system must be added
for hazardous and non-hazardous landfills as follows:
n Artificial sealing liner
n Drainage layer ≥ 0.5m
If, on the basis of an assessment of environmental risks…the competent authority has decided…that
collection and treatment of leachate is not necessary or it has been established that the landfill poses no
potential hazard to soil, groundwater or surface water, the above requirements…may be reduced accordingly.
Appropriate measures shall be taken…to:
n control water from precipitations entering into the landfill body
n prevent surface water and/or groundwater from entering into the landfilled waste
n collect contaminated water and leachate [if an assessment…shows that the landfill poses no potential
hazard to the environment, the competent authority may decide that this provision does not apply]
n treat contaminated water and leachate collected from the landfill to the appropriate standard required
for their discharge
The above provisions may not apply to landfills for inert waste.
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6.1 Introduction
Municipal solid waste (MSW) landfill leachate typically
contains elevated levels of, amongst other things,
biochemical oxygen demand, ammonia, chloride, heavy
metals and organic pollutants and poses a significant
risk to ground and surface waters if not properly
controlled. The lining system for a landfill provides
a barrier which contains leachate and prevents it
impacting on the environment. Leachate is required to
be collected and treated to an appropriate standard for
discharge.
6.2 Pre-EPA licensing
Environmental Protection Agency (EPA) inspections of
27 MSW landfills in 1997 found that only 26% had
engineered liners and 33% were collecting leachate.13
There was no on-site treatment and the collected
leachate was either tankered or discharged via sewer to
municipal urban wastewater treatment plants. Evidence
of leachate discharges to surface waters, leachate
contamination or leachate seepages were found
at 67% of the landfills and build up of leachate or
contaminated surface water in bunds, ditches, ponds,
drains or cut-off channels at 52%.
6.3 Implementation of lining & leachate management requirements
Licence requirements
EPA licence requirements for landfill lining are generally
the same as those specified in the Landfill Directive.
In the case of MSW landfills, the EPA specifies the
drainage layer in more detail and requires a geotextile
protection layer. Reduced specifications have been
allowed at a limited number of integrated pollution
prevention and control (IPPC) landfills in particular
following risk assessments as provided for in the
Landfill Directive. For example, a liner consisting of a
geo-synthetic clay liner (GCL) overlain by a synthetic
drainage layer was agreed for three ash landfills
(Clonbulloge Ash Repository, ESB Lough Ree and ESB
West Offaly). Also, a liner consisting of a conditioned
mix of Flue Gas Desulphurisation (FGD) waste, coal
ash and cement placed in compacted raises to 1
metre such that permeability does not exceed 1 x 10-9
m/s was agreed for the ESB Moneypoint Flue Gas
Desulphurisation (FGD) waste landfill. In addition, as
detailed in Chapter 3, the absence of liners at seven of
the older (inert and IPPC) landfills is being reassessed
as part of a licence review process.
Requirements with respect to leachate management
are much more explicit in EPA MSW landfill licences
than in the Landfill Directive and include the following
where relevant:
n Provision and maintenance of leachate
management infrastructure
n Enclosure of leachate storage/treatment structures
n Leachate levels not to exceed a level of 1.0 metre
over the top of the liner
n A minimum freeboard of 0.5 metres be maintained
in the final leachate holding structure
n Recirculation of leachate only be undertaken with
EPA agreement
n EPA approved agreements required for off-site
removal and treatment
n Compliance with limit values for discharges of
treated leachate to surface waters
n Monitoring of leachate levels and quality
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EPA MSW landfill licences also contain specific
conditions regarding installation of capping (see
Chapter 7) which is an important factor in limiting the
generation of leachate in the first instance. In addition,
both lining and leachate management systems are
specified engineering works under EPA MSW landfill
licences and accordingly are subject to the satisfactory
completion of the following before the EPA will agree
to the use of any new landfill cell:
n detailed proposals must be submitted for prior EPA
agreement
n works must be supervised by a qualified person
who is present at all times
n construction quality assurance must be carried out
and reported to the EPA
Leachate collection and treatment is not required at inert
landfills due to the nature of the wastes, as allowed for
under the Landfill Directive. Both mono landfills collect
leachate. Leachate from Tradaree Point E.T.P. is pumped
back to the Tradaree Point wastewater treatment plant.
Leachate from Clonbulloge Ash Repository is permitted
to be discharged to surface water when sufficient
dilutions are available–pH adjustment is required before
discharge and the emission limit values are specified for
pH, suspended solids and toxicity.
Leachate is collected at some of the IPPC landfills (e.g.
Gypsum Industries Limited), however, leachate is not
collected at the majority. While this is not an issue for
the IPPC landfills that landfill inert waste, the EPA is
assessing the other IPPC landfills that are not collecting
leachate and will require leachate collection if necessary.
Enforcement
Lining of landfills and leachate management has been
a significant enforcement issue for the EPA40,41 and
major emphasis has been placed on enforcement of the
relevant licence conditions since licensing commenced.
Landfill lining and leachate management requirements
are enforced through the review and approval of
relevant specified engineering works proposals and
construction quality assurance reports and through
audit and inspection. In addition, landfill operators are
required to monitor leachate and ambient groundwater
and surface water and the EPA conducts verification
monitoring. Seven successful prosecutions were taken
between 2004 and 2009 for offences relating to
inadequate leachate management (Table 6.1).
Enforcement of EPA licence conditions with respect
to lining and leachate management has resulted in
significant progress since the EPA commenced licensing
of landfills. By 16th July 2009 (the latest date for
compliance with Landfill Directive requirements), all
open MSW landfills were landfilling in lined cells. This
progression in lining of landfills represents a significant
investment and it is estimated that in excess of 150
hectares of lining was installed in MSW landfills in
Ireland up to the end of 2008. The cost in developing
landfill cells to full Landfill Directive/EPA waste licence
specification is considerable. South Dublin County
Council reports that the contracts for the development
of the landfill cells at Arthurstown Landfill totalled
€23.3 million.42 In addition, approximately 1.4 million
cubic metres of MSW leachate was collected for
treatment from MSW landfills in Ireland in 2008, 1
million cubic metres from open MSW landfills and 0.4
million cubic metres from closed MSW landfills. 99%
of this leachate was either tankered or discharged
via sewer to urban wastewater treatment plants
(Table 6.2). The remaining 1% was sent to two private
facilities or treated on-site and discharged to water.
On-site leachate treatment was carried out at six
open MSW landfills in 2008 and mainly consisted of
aeration/air-stripping of methane before consignment
to urban wastewater treatment plants. One MSW
landfill is treating leachate using aeration/settlement/
sand-filtration and discharging to surface water – the
licence for this landfill limits the rate of discharge of the
treated leachate and the levels of pH, BOD, suspended
solids, phosphorus and ammonia.
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Office of Environmental Enforcement (OEE)
There remain, however, a number of significant issues to
address with respect to leachate management at landfills.
In 2008/2009, the EPA issued 69 non-compliances
relating to management of leachate and contaminated
water. The most significant issues arising were:
n Failure to maintain leachate head ≤1m above the
basal liner
n Emissions related non-compliances, e.g. non-
compliant emissions to surface water, groundwater
or sewer
n Failure to provide adequate leachate management
infrastructure
The phased introduction of an EPA authorisation
system for urban wastewater treatment plants
commenced in December 2007. The need for emissions
from urban wastewater treatment plants to meet
authorised emission limit values may limit their capacity
to treat landfill leachate and on-site treatment of
landfill leachate may become increasingly necessary.
Benefits of reducing tankering of leachate include
reduced greenhouse gas emissions and transport costs.
Table 6.1Landfills prosecuted by the EPA for inadequate leachate management – 2004 to 2009 (years for which consolidated records are available)
Licensee Landfill Year*
Cavan Co. Co. Corranure Landfill 2007
Waterford City Council Kilbarry Landfill Site 2006
Limerick City Council Longpavement 2005
Offaly Co. Co. Derryclure Landfill 2005
Monaghan Co. Co. Scotch Corner 2005
Cavan Co. Co. Corranure Landfill 2005
Dundalk Town Council Dundalk Landfill 2004
*There were no relevant prosecutions 2008 and 2009
Table 6.2Urban wastewater treatment plants receiving MSW landfill leachate in 2008
Urban wastewater treatment plant
Athy Cashel Mohill Purcellsinch
Athlone Castelbar Monahgan Ringsend
Ballinasloe Castletroy Mortarstown Roscommon
Ballaghaderreen Cavan Muinebheag Shanganagh
Ballina Charleville Mullingar Sixmilebridge
Ballybay Clonmel Mutton Island Swords
Baltinglass Drogheda Navan Tralee
Bandon Dungarvan Nenagh Tuam
Bray Enniscorthy Newcastle West Tullamore
Limerick City Enniskerry Osberstown Waterford City
Carrick on Shannon Leixlip Portlaoise Wexford
Carrigrennan Letterkenny Purcellsinch
Carrigtohill Lisdoonvarna Portlaoise
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Figure 6.1Installation of liner at MSW landfill
Figure 6.2Testing of welds on liner at MSW landfill
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
7. Landfill cover & capping
7.1 Introduction
Landfill cover and capping perform a number of
important functions. Daily and intermediate cover is
applied during the operational phase and mitigates
against nuisance caused by odour, litter, vermin, etc.
When a cell is filled, temporary capping is applied first
to allow time for settlement and final capping is applied
following settlement. The main functions of the capping
system are to:
n Minimise the infiltration of water into the waste
and thus the generation of leachate
n Provide for the capture and management of
landfill gas
n Provide a physical separation between the waste
and plant and animal life
7.2 Pre-EPA licensing
Environmental Protection Agency (EPA) inspections of
27 municipal solid waste (MSW) landfills in 1997 found
that covering of waste was carried out at 30% of the
landfills inspected.13
Landfill Directive
Annex I requires that:
Measures shall be taken to minimise nuisances and hazards arising from the landfill through:
n emissions of odours and dust
n wind-blown materials
n noise and traffic
n birds, vermin and insects
n formation and aerosols
n fires
… Protection of soil, groundwater and surface water is to be achieved by the combination of a geological
barrier and a top liner during the passive phase/post closure.
The following minimum requirements for final capping of landfills for non-hazardous waste:
n Topsoil cover > 1m
n Drainage layer > 0.5m
n Impermeable mineral liner
n Gas drainage layer
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7.3 Implementation of cover & capping requirements
Licence requirements
The types of cover/capping applied at landfills are
defined in Table 7.1.
EPA MSW landfill licences require that daily cover is
applied at the end of each working day and intermediate
cover where waste is left for extended periods.
Temporary capping is installed in areas where landfilling
is completed until such time as the waste body has
settled sufficiently to allow final capping. In addition,
it is best practice when installing temporary capping
to include a gas barrier membrane and a sacrificial
gas barrier membrane on the interfaces between the
cell being capped and future cells. EPA MSW landfill
licences currently require installation of final capping
within 12-14 months of completion of landfilling in a
cell. The specification for final capping at MSW landfills
is consistent with the Landfill Directive requirements for
non-hazardous landfills and is as follows:
n 1 metre of soil
n Drainage layer of 0.5 metre thickness having a
minimum hydraulic conductivity of 1 x 10-4 m/s or
a geosynthetic material that provides equivalent
transmissivity
n Compacted mineral layer of a minimum 0.6 metre
thickness with a permeability of less than 1 x 10-9
m/s or a geosynthetic material (e.g. LLDPE) or
similar that provides equivalent protection
n Gas collection layer of natural material (minimum
0.3 metres) or a geosynthetic layer
In addition, capping is a specified engineering work
under MSW landfill licences and is subject to the
satisfactory completion of the following:
n detailed proposals must be submitted for EPA
agreement
n works must be supervised by an appropriately
qualified person who is present at all times during
the works
n Construction quality assurance (CQA) must be
carried out and reported to the EPA
Cover is not generally required for the inert, mono and
integrated pollution prevention and control (IPPC) landfills
due to the nature of the wastes deposited. However,
measures are required where necessary to prevent dust
emissions. There are no specifications in the Landfill
Directive for capping of landfills for inert waste. EPA
inert landfill licences require 1 metre of soil as final
capping. Specifications for final capping of mono landfills
and IPPC landfills vary but the general requirement has
been for a layer of soil 0.5 metres to 1 metre thick.
Table 7.1Descriptions of cover and capping terms based on EPA guidance manuals and EPA licences
Daily cover
Daily cover is material placed over deposited waste
at the end of each day (about 150mm if soil cover
is used). The objective is to minimise odour, the
amount of litter generated and to control flies
and access to the waste by birds and vermin.
Intermediate cover
Intermediate cover is material other than daily
cover placed over deposited waste for a period
of time prior to temporary capping (minimum
of 300mm if soil is used).
Temporary capping
Temporary capping is installed in completed areas
until such time as the waste body has settled
sufficiently to allow final capping to be installed.
Temporary capping should be at least 0.5m thick.
Final capping
Final permanent capping – see text for specifications.
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Enforcement
An EPA survey of 27 MSW landfills in 2008 found that
cover is applied at all landfills.43 The range of materials
used was extensive and included:
n Soil
n Construction and demolition fines
n Shredded wood
n Composted material
n LDPE/PE
n Hessian
n Automobile shredder residue
n Ash
n Foams/sprays
n Peat
n Quarry sand/gravel
However, the survey found that cover materials were
not applied correctly on open areas in 50% of the
landfills with the following issues noted:
n Inadequate cover material depth, e.g. waste visible
n Inadequate application and compaction, e.g.
material poorly compacted and application depth
not uniform
n Poor preventative maintenance following
storm water conditions resulting in etching and
channelling within the cover material
Application and maintenance of cover on side slopes
was found to be a particular problem.
There are various advantages and disadvantages
associated with different cover materials and it is
important that landfills have a cover management
plan to ensure the required objectives are met. Proper
application of cover materials will continue to be
enforced by the EPA during inspections and audits
of landfills. In addition, the EPA held a workshop
for landfill operators in October 2009 at which best
practice in relation to daily and intermediate cover
was presented and the EPA intends to develop further
guidance in 2010. The workshop presentation can be
viewed on video via the EPA website:
http://www.epa.ie/downloads/videos/
wasteworkshop/
In 2009, the EPA required that EPA agreed cover
management plans must be in place when fabric
based daily cover is used. This was due to concerns
in relation to the ability of these materials to prevent
nuisance when used in isolation as cover. The cover
management plans must specify the:
n Areas in which fabric based cover can be used
(limited to areas where waste exposure is for one
night only)
n Criteria for placement of the fabric based cover
(e.g. overlap, stapling of joins and use of soils to
weigh down the material)
n Daily inspection regime
n Remediation measures in the event of odour or
fly nuisance (including covering of waste with soil
or other suitable cover material where problems
persist)
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The failure to install capping in a timely manner has
been a significant enforcement issue for the EPA.40,41
Capping requirements are enforced through the review
and approval of relevant specified engineering works
proposals and construction quality assurance reports
and through audit and inspection. In 2005, charges
were brought against the operators of Kilbarry Landfill
Site and Tramore Waste Disposal Site for failing to install
capping within the timeframe specified in the licences
(other charges were brought in relation to landfill gas
and leachate management). These cases were heard
at Circuit Court level due to the seriousness of the
offences. The outcome of the cases was fines totalling
€10,000 and the award of costs totalling €23,520.
A review of progress at the end of 2008 shows that
there is a high rate of completion of capping at MSW
landfills. The amount of capping at MSW landfills open
in 2008 was approximately 169 hectares (61%) final
capped, 82 hectares (30%) temporary capped and 24
hectares (9%) uncapped, i.e. active areas subject to
daily/intermediate cover (Figure 7.1). However, there
are still a number of MSW landfills that have not
installed final capping within the specified timeframes.
The EPA issued Notifications of Non-Compliance to
seven MSW landfills in 2008/2009 for failure to meet
the deadlines specified in the licences for final capping/
restoration:
n Waterford City Council, Kilbarry Landfill Site
n Monaghan County Council, Scotch Corner Landfill
n Kerry County Council, North Kerry Landfill Site
n Kilkenny County Council, Dunmore Landfill
n Kildare County Council, Silliot Hill Landfill
n Westmeath County Council, Marlinstown Landfill
n Galway City Council, Carrowbrowne Landfill Site
Failure to install capping as required is considered a
significant issue by the EPA and will continue to be
enforced. Court actions will be taken if necessary.
Uncapped area9%
Note: Total area (uncapped + temporary + final capped) = 275Ha
Temporarycapped area
30%
Final capped area61%
Figure 7.1Capping at open MSW landfills in 2008
Figure 7.2Installation of final cap at MSW landfill
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
8. Landfill gas management & odour control
8.1 Introduction
Landfill gas is principally composed of methane (up to
65% by volume) and carbon dioxide (up to 35% by
volume) and contains many minor constituents at low
concentrations (typically less than 1% volume contains
120-150 trace constituents). Risks posed by landfill gas
include:
n flammability and explosion risks
n asphyxiation risks
n potential health impacts due to many minor
constituents present at low concentrations
n odour impacts from trace constituents, e.g.
hydrogen sulphide and mercaptans
n environmental impacts due to the global warming
potential of methane and carbon dioxide
n vegetation dieback
Given these risks, it is important that landfill gas is
contained and collected to minimise migration off-site
and that the collected gas is utilised or flared.
8.2 Pre-EPA licensing
Environmental Protection Agency (EPA) inspections of
27 municipal solid waste (MSW) landfills in 1997 found
that only 4 (15%) had active gas extraction with three
of those using the landfill gas to generate electricity
and a further one flaring the gas mainly to alleviate
odour problems.13
8.3 Implementation of gas management requirements
Licence requirements
EPA MSW licences require the following with respect
to landfill gas management:
n Provision and maintenance of gas management
infrastructure
n All buildings constructed in accordance with
Department of Environment 1994 publication
Protection of New Buildings and Occupants from
Landfill Gas
n The utilization of landfill gas where feasible,
otherwise landfill gas must be flared
Landfill Directive
Annex I requires that:
Landfill gas shall be collected from all landfills receiving biodegradable waste and the landfill gas must be
treated and used. If the gas collected cannot be used to produce energy, it must be flared.
The collection, treatment and use of landfill gas shall be carried on in a manner which minimises damage to
or deterioration of the environment and risk to human health
Measures shall be taken to minimise nuisances and hazards arising from…emissions of odours…
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n The flaring of landfill gas must be in an enclosed
flare with a burn chamber residence time of
minimum 0.3 seconds and burn temperature of
minimum 1000ºC. The use of open flares is only
acceptable as an interim measure on a temporary
basis and with prior EPA agreement
n Compliance with specified limit values for
emissions from flares and utilization plant
n Monitoring of landfill gas
The principal treatment for landfill gas at MSW landfills
is flaring. A 2008 survey of MSW landfills by the EPA
for this report identified that flares were operated at
all of the 31 MSW landfills open that year apart from
two who had just commenced waste disposal, flares
were operated at 18 of the closed MSW landfills and
landfill gas was not collected at the remaining 18
closed MSW landfills. In relation to the latter 18, flaring
is not required at the majority due to factors such as
the limited quantities of waste deposited, the age of
waste, etc. and they are authorised to passively vent
landfill gas to atmosphere to prevent lateral migration.
Table 8.1Landfills prosecuted by the EPA/DPP for inadequate landfill gas management – 2004 to 2009 (years for which consolidated records are available)
Licensee Landfill Year*
Cavan Co. Co. Corranure Landfill 2007
Waterford County Council Tramore Waste Disposal Site 2006
Waterford City Council Kilbarry Landfill Site 2006
Limerick City Council Longpavement 2005
Offaly Co. Co. Derryclure Landfill 2005
Monaghan Co. Co. Scotch Corner 2005
Cavan Co. Co. Corranure Landfill 2005
Dundalk Town Council Dundalk Landfill 2004
*There were no relevant prosecutions 2008 and 2009
Enforcement
Landfill gas management has been a significant
enforcement issue for the EPA.40,41 Landfill gas
management infrastructure and its installation are
enforced through the review and approval of specified
engineering works proposals and construction quality
assurance reports submitted by landfill operators and
through audit and inspection. In addition, landfill
operators are required to monitor landfill gas emissions
and ambient landfill gas levels. Verification monitoring
is conducted by the EPA to ensure the accuracy of the
data submitted. Eight successful prosecutions were
taken between 2004 and 2009 for offences relating to
inadequate landfill gas management (Table 8.1).
However, flaring is possible at two of theses sites and
enforcement action is ongoing to require the provision
of landfill gas collection and flaring infrastructure at
those landfills. The EPA requires the use of enclosed
flares as these can maintain sufficient temperature
and residence time to meet the emission standards
that apply. EPA guidance does provide for the use of
open flares but only as a temporary measure. The 2008
survey identified there were 58 enclosed flares and
seven open flares at MSW landfills. The open flares
were generally only in temporary use or maintained
as backup to an enclosed flare. Only one site was
identified that operated an open flare solely and that
was replaced with an enclosed flare in 2009.
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Figure 8.1Enclosed flare
There were seven EPA licensed MSW landfills and
one unlicensed landfill using landfill gas to generate
electricity in 2008 with a total capacity of approximately
29MW (Table 8.2). There were some minor changes
in 2009: landfill gas was not utilised at Silliot Hill
Landfill during 2009 but utilisation may recommence
if gas quality improves; operation of a 1MW engine
commenced at Gortadroma Landfill Site in mid-2009.
The EPA is aware of plans to commence generation
at four other MSW landfills during 2010: Knockharley
Landfill, East Galway Residual Landfill Site, Ballynagran
Residual Landfill and North Kerry Landfill.
Figure 8.2Landfill gas utilisation plant
Table 8.2MSW landfills using landfill gas to generate electricity in 2008
Licensee Landfill No of Engines Power
capacity (MW)
South Dublin Co. Co. Arthurstown Landfill 11 14.2
Fingal Co. Co. Balleally Landfill 5 5
Cork City Council Kinsale Road Landfill 1 1
KTK Landfill Limited KTK Landfill Limited 3 3.75
Dun Laoghaire-Rathdown Co. Co. Ballyogan Landfill Facility 2 2
Fingal Co. Co. Dunsink Landfill 1 1.25
Kildare Co. Co. Silliot Hill Landfill 1 1.25
South Dublin Co. Co. Friarstown* 1 0.6
Total 25 29
*This landfill closed in 199748 and does not come under an EPA waste licence. It has been entered on the register
of sites under the Waste Management (Certification of Historic Unlicenced Waste Disposal and Recovery Activity)
Regulations, 2008 (see Section 2.3). Data regarding engine from presentation by Bioverda Power Systems.49
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
The increased flaring and utilisation of landfill gas has
resulted in decreased emissions of methane from the
landfill sector despite increased landfilling of waste,
with landfill gas flaring and utilisation offsetting more
than 60 percent of landfill methane production in
2008 (Figure 8.3).44,45 As a result, greenhouse gas
(GHG) emissions from landfills decreased by 20% from
1,173ktCO2eq* in 1990 to 936ktCO2eq in 2008 (1.4%
of total Irish GHG emissions). This in turn has meant
that the largest relative reduction in GHG emissions in
Ireland from 1990 to 2008 was in the waste sector**
(Figure 8.4). GHG emissions in all other sectors except
agriculture increased over this period.
* CO2 equivalent: greenhouse gases other than CO2 (i.e. methane, nitrous oxide and so-called F gases) may be converted to CO2 equivalent using their global warming potentials.44,45
** GHG emissions data are typically broken down by the following sectors: energy; residential; industry and commercial; agriculture; transport; waste. GHG emissions from landfills were 85.5% of GHG emissions from the waste sector in 2008
Figure 8.3Methane emissions from landfill 1990-200845
0
20,000
40,000
60,000
80,000
100,000
120,000
140,000CH4 UtilisationCH4 Flaring
2008200720062005200420032002200120001999199819971996199519941993199219911990
CH4 GenerationCH4 Emissions
Tonn
es M
etha
ne
Figure 8.4Greenhouse gas emissions in Ireland 1990-200844
0
5,000
10,000
15,000
20,000
25,000
WasteTransportAgriculture Industry/Commercial ResidentialEnergy
2008200720062005200420032002200120001999199819971996199519941993199219911990
kt C
O2e
q
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Office of Environmental Enforcement (OEE)
While the management of landfill gas has improved over
the years, it remains a significant issue. In 2008/2009,
the EPA issued 43 non-compliances relating to landfill
gas management. The most significant issues were:
n Failure to operate flares properly, e.g. issues such
as flares being non-operational, of inadequate
capacity or being operated at inadequate
combustion temperatures
n Failure to maintain and manage the landfill gas
collection system so that it performs adequately,
e.g. issues such as condensate build-up and gas
well maintenance
Sustainable Energy Ireland predicted that the accessible
landfill gas resource would be 80MW in 2010 which
indicates that there is potential for significant additional
utilisation of landfill gas.46 Furthermore, at the end of
2009 landfill gas was utilised at landfills with greater
than 1 million tonnes of total waste disposed* whereas
the UK Environment Agency consider 200,000 tonnes
of total waste disposed as an indicative benchmark for
landfill gas utilisation.47 There are 32 MSW landfills with
greater than 200,000 tonnes of waste disposed that
were not utilising landfill gas at the end of 2009, at least
15 of which had greater than 500,000 tonnes disposed.
The EPA is aware of plans to commence utilisation
at a further four landfills in 2010. While there are
factors other than the quantity of waste that affect the
feasibility of utilisation of landfill gas (e.g. age of waste,
biodegradable content of waste, methane content of
gas, site geometry, grid access), there exists greater scope
to exploit this resource and every effort should be made
by landfill operators in this regard. As such, the EPA will
continue to encourage the use of this resource in 2010.
Figure 8.5IT based data management system for interpretation of gas field balancing results
* All MSW landfills with greater than 1 million tonnes of total waste disposed were utilising or had utilised landfill gas whereas no MSW landfill below 1 million tonnes had utilised landfill gas as of end of 2009.
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8.4 Odour control
Landfills are currently operated to much higher
standards than previously with improved design,
infrastructure, management and monitoring. However,
BMW is disposed of in a fewer number of larger-scale
landfills resulting in significantly higher rates of landfill
gas generation on a site-specific basis. The effective
management of potential odour nuisance requires
tight control in relation to covering waste, installation
and operation of landfill gas infrastructure and other
mitigation measures. Failure by landfill operators in this
regard leads to odour nuisance for residents living near
landfill facilities.
Odour from landfills, in particular from open MSW
landfills, has become the single biggest cause of
complaint to the EPA accounting for 71% of all
complaints in relation to all waste and IPPC licensed
facilities in 2009 (Figure 8.6). The total number of
odour complaints received by the EPA in relation to
open MSW landfills increased more than 10-fold from
94 in 2004 to 1568 in 2009. Table 8.3 lists all landfills
for which the EPA received more than 20 odour
complaints in 2009. These eight landfills accounted for
99% of the MSW landfill odour complaints received in
2009.
All complaints in relation to all Waste & IPPC licensed activities
MSW landfill odour complaints
0
500
1,000
1,500
2,000
2,500
200920082007200620052004
Figure 8.6MSW landfill odour complaints versus total complaints in relation to waste and IPPC licensed activities, 2004 – 2009
Table 8.3Landfills for which the EPA received more than 20 odour complaints in 2009
Licensee Landfill No. of odour complaints
2008 2009
Cavan Co. Co. Corranure Landfill* 235 613
Greenstar Holdings Limited Knockharley Landfill 362 311
Neiphin Trading Limited Kerdiffstown 87 308
Roscommon Co. Co. Ballaghaderreen Landfill* 63 118
Cork Co. Co. Youghal Landfill 127 90
Westmeath Co. Co. Ballydonagh Landfill 6 49
Greenstar Holdings Limited Ballynagran Residual Landfill 48 46
Greenstar Holdings Limited East Galway Residual Landfill Site* 117 25
*Landfills previously prosecuted in relation to odour (see Table 8.4)
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
In response to the increase in odour complaints,
the EPA has dedicated significant resources towards
regulating odour from landfills. The following are some
of the initiatives taken by the EPA in recent years:
Assessment & enforcement
n The EPA has taken seven successful prosecutions in
relation to odour impact (Table 8.4) and submitted
three files to the Director of Public Prosecutions
(DPP) in 2009.
n Corranure Landfill was temporarily closed
for a two-week period in 2008 to facilitate
the installation of vital infrastructure for the
management of landfill gas arising at the facility.
n There has been a significant level of odour related
assessments, inspections and audits including
deployment of site agents (Box 8.1)
n The EPA has deployed external experts to assess
landfill gas management at MSW landfills
(see Box 8.2).
n The EPA developed guidance on odour impact
assessment.51 This provides a basis for a consistent
and systematic approach to odour assessment and
reporting and for assessment of compliance with
licence conditions relating to odour control.
Table 8.4Landfills prosecuted by the EPA in relation to odour impact – 2004 to 2009 (years for which consolidated records are available)
Licensee Landfill Year*
South Dublin County Council Arthurstown Landfill 2009
Greenstar Holdings Limited East Galway Residual Landfill Site 2009
Roscommon County Council Ballaghaderreen Landfill 2008
Cavan County Council Corranure Landfill 2007
Ballinasloe Town Council Pollboy Landfill Facility 2006
Monaghan County Council Scotch Corner Landfill 2005
Roscommon County Council Ballaghaderreen Landfill 2005
*There were no relevant prosecutions in 2004
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Box 8.1 Focus on use of site agents
The EPA deploys site agents to investigate odour
issues at landfills. Site agents are typically deployed
for a number of days at a particular landfill during
which the site agent assesses odour management
on an ongoing basis and is available to residents
and the EPA to verify odour complaints. During
2007-2009, a total of four person-months were
spent on-site at landfills with odour issues. This is
in addition to office based time associated with
the preparation of notices of non-compliance and
evidence for court proceedings.
Box 8.2 Focus on external expert assessment
& surface emissions monitoring
The EPA uses external experts to assess landfill
gas management systems at landfills and conduct
surface emissions monitoring. This consists of audits
of landfill gas infrastructure/management and
monitoring of surface VOC emissions (Figures 8.7 &
8.8). This commenced with assessment of 10 landfills
in 2007, stepping up to cover 25 landfills in 2008
and 29 landfills in 2009. Reports were prepared and
issued to all operators setting out any mitigation
measures required and the results of the 2009
assessments were published by the EPA in 2010.50
Over half of the landfills assessed in 2009 showed
improvements in terms of reduced surface emissions
when compared to 2008 surveys (Figure 8.9). The
most common issues identified from the surveys
were emissions from flanked surfaces, inadequate
sealing around gas wells and emissions associated
with leachate management systems.
The EPA is developing guidance on surface
emissions monitoring in 2010.
Figure 8.7Monitoring of surface emissions from the flank of a landfill cell
Figure 8.8Landfill surface emissions map showing results of monitoring
No Improvements7
Improvements14
Minor Improvements6
Figure 8.9Changes in surface emissions at landfills surveyed in 2008 and 2009
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Improving standards
n The EPA has reviewed MSW landfill licences with
odour issues to ensure that odour management
planning and control is carried out in a
comprehensive manner (see Chapter 3). Each MSW
landfill should develop an odour management
plan (OMP) that should address the following
as a minimum:
• Resources and training
• Acceptance and management of odorous waste
deliveries
• Independent assessment and reporting on
surface VOC emissions
• Use of sacrificial gas extraction systems, phased
capping of the waste body and interim capping
at inter-cell boundaries
• Working face/active cell sizing and covering
• Landfill gas collection:- locations of infrastructure
including access/haul roads, well design and
density, monitoring, condensate management,
field balancing, flare/combustion plant operation
• Identification and mitigation of fugitive sources
of landfill gas emissions, e.g. from leachate
management infrastructure
• Monitoring:- VOC surface emissions from
capped areas, odour checks off- and on-site,
receipt and evaluation/verification of odour
complaints received
• Monthly review and reporting of odour control
measures in place at the facility to include
review of odour complaints, monitoring results,
landfill gas control infrastructure/management
and remedial/corrective actions
n There is a strong link between BMW landfilled
and landfill gas/odour generated. As such, the
implementation of the Landfill Directive requirements
in relation to diversion of BMW from landfill (Chapter
4) should lead to reduced landfill gas emissions
and thus reduced odour in the coming years.
n The EPA held a waste workshop in October
2009 which was attended by 183 delegates and
addressed a range of topics including diversion of
BMW, effective landfill gas management and use of
cover materials. Presentations by EPA speakers are
available as video broadcasts on the EPA website:
http://www.epa.ie/downloads/videos/
wasteworkshop/#d.en.28003
n An important factor in relation to odour nuisance
is the location of the landfill with respect to
sensitive receptors. The Landfill Directive requires
that the location of a landfill must take into
consideration the distances from the boundary of
the site to residential and recreation areas. The
landfill can be authorised only if the characteristics
of the site or the corrective measures to be taken
indicate that the landfill does not pose a serious
environmental risk. Set-back when locating landfills
is being considered as part of the current process
to derive landfill best available techniques (BAT).
The current draft landfill BAT recommends a set-
back distance of 750m.
Liaison with local residents
n The EPA continues to meet with local residents,
community groups, and public representatives
in order to communicate and focus on residents
concerns with a view to improving environmental
performance at the landfills. These include
open forum public meetings, meetings on site
with residents and meetings on an individual
basis. It should be noted, however, that EPA
communications may be restricted in circumstances
where legal cases may arise or are in progress.
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9.1 Introduction
The landfilling of waste poses a potential long-term
threat to the environment. Landfills should be located,
designed, operated and monitored to ensure that they
do not to any significant extent:
n Harm the environment
n Endanger human health
n Create an unacceptable risk to water, soil,
atmosphere, plant or animals
n Create nuisances through noise or odours, or adversely
affect the countryside or places of special interest
Monitoring is necessary throughout the life of a landfill
from the pre-operational stage through the operational
stage and into the aftercare stage. Environmental
Protection Agency (EPA) licences specify monitoring
programmes covering the following as appropriate:
n Surface water
n Ground water
n Leachate
n Landfill gas and landfill gas combustion products
n Meteorological conditions
n Odours
9. MONITORING
This chapter covers the implementation of monitoring requirements only and does not cover the results of monitoring which has been used to inform the relevant sections above and in particular Chapter 6 and 8.
Landfill Directive
Article 12 requires that:
The operator of a landfill shall carry out during the operational phase a control and monitoring programme as
specified in Annex III. Annex III of the Landfill Directive specifies the monitoring requirements for the following
aspects of landfills:
n Meteorological
n Surface water
n Groundwater
n Leachate
n Landfill gas
n Topography/stability
The operator shall notify the competent authority of any significant adverse environmental effects revealed by
the control and monitoring procedures and follow the decision of the competent authority on the nature and
timing of the corrective measures to be taken…
…At least once a year, the operator shall report, on the basis of aggregated data, all monitoring results to the
competent authorities…
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n Noise
n Dust/particulate matter
n Ecology
n Landfill stability and topography
The EPA published revised guidance on landfill monitoring
in 2003 which is available on the EPA website:
http://www.epa.ie/downloads/advice/waste/waste/
name,26169,en.html
Figure 9.1EPA Landfill Manuals: Landfill Monitoring, 2nd Edition5
9.2 Incidents & reporting
EPA licences require that monitoring results are
submitted at specified frequencies with a summary
report submitted annually – referred to as an Annual
Environmental Report (AER). Since 2009, AERs are
available through the EPA website.
In addition, landfill operators are required to notify the
EPA of any incident which is typically defined as:
n An emergency
n Any emission which does not comply with the
requirements of the licence
n Any exceedance of the daily duty capacity of waste
handling equipment
n Any trigger level specified in the licence which is
attained or exceeded
n Any indication that environmental pollution has, or
may have, taken place
In determination of the significance of incidents, landfill
operators are required to classify incidents as follows:
Category 1
An environmental incident, which is causing, has
caused or which could have caused significant
environmental damage or significant environmental
risk or hazard to the public or to the general
environment. Incidents that fall into this category are
those having any of the impacts listed below:
n Significant effects on water quality
n Significant effects on air quality
n Major damage to an ecosystem
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n Closure of potable water extractors
n Reduction in amenity value of an area
n Damage to agriculture or commerce
n Impact on local residents or community
n Urgent remedial action necessary
Category 2
A minor environmental incident with typical impacts:
n Local impact to water or land
n Notification to and precautionary short-term
closure of potable water extractions required
n Public warnings not required
n Effect on air quality as evidenced by odour
complaints
Category 3
An environmental incident where there was never
at any time any damage injury or significant risk
or exposure to hazard to the public or the general
environment.
In the event of an incident occurring at a facility, the
landfill operator must notify and submit a record by
fax to the EPA. Category 1 and 2 incidents are typically
published on the EPA web site where warranted:
http://www.epa.ie/news/incidents/
9.3 Surface water
Surface water comprises of rainwater from
uncontaminated areas and ambient surface water.
The main risk of contamination of the surface water
is from non-compliant discharges of leachate with
other potential sources consisting of contaminated
run-off or accidental spillages of materials used on
site such as fuels. The Landfill Directive requires at
least two monitoring locations, one upstream and one
downstream of the landfill. EPA landfill licences specify
the location, parameters and frequency of surface
water monitoring. While monitoring requirements are
site-specific, typical requirements for MSW landfills are
a weekly visual/odour inspection, quarterly monitoring
for core parameters such as conductivity, temperature,
COD/BOD, ammonia, suspended solids and chloride
with annual monitoring for other parameters.
Chemical analysis of surface water is essential in
identifying possible contaminants and in quantifying
their concentrations and provides an instantaneous
picture of water quality. Since some contaminants
can interact and occur in complex mixtures, such
analyses alone will give little indication on the potential
biological impacts. Therefore, landfill operators may
also need to complete biological assessments on the
quality of surface water around landfills. Analysis of
the macro-invertebrates that inhabit the substrata
is satisfactory for routine biological water quality
monitoring. As pollution increases there is a decrease
in the faunal diversity with an increase in the numbers
of pollution tolerant forms. The biological information
gathered is presented as a biotic index, which relates
the benthic community composition and water quality.
This five point scale ranges from Q1–Q5 with Q5 being
unpolluted and Q1 being seriously polluted.
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Figure 9.2Surface water management infrastructure
9.4 Groundwater
Ground water is that part of the subsurface water
which is in the saturated zone. It is a major natural
resource and its protection is of prime importance.
The purpose of groundwater monitoring at landfills
is to assess the groundwater quality and quantity
and in the process determine the effectiveness of the
environmental control systems. The monitoring points
must provide information on the groundwater likely
to be affected with at least one monitoring point
upgradient and two downgradient of the landfill.
The Landfill Directive specifies that the groundwater
composition and level that must be tested at specific
frequencies depending on the operation phase of the
landfill. EPA licences specify the location, parameters
and the frequency of groundwater monitoring. While
monitoring requirements are site-specific, typical
requirements for MSW landfills are monthly monitoring
of groundwater level, quarterly monitoring of
ammonia, chloride, dissolved oxygen, pH, temperature
and total organic carbon and annual monitoring of
metals, sulphates, alkalinity, total oxidised nitrogen and
faecal coliforms.
The Landfill Directive states that significant adverse
effects should be considered to have occurred when an
analysis of the ground water shows significant change
in the water quality and requires that trigger levels are
established. Trigger levels should take hydrogeological
conditions and the background groundwater quality
into account. A review by the EPA of open MSW
landfills in 2008 identified that approximately one-third
had not established trigger levels. In some cases, not
all of the EPA licences provided for the establishment
of trigger levels and these licences are being amended
accordingly (Chapter 3).
9.5 Leachate
Understanding the volume and composition of the
leachate allows for effective environmental protection.
The Landfill Directive stipulates that the leachate
volume and composition must be monitored at specific
frequencies, which are dependant on the operation
phase on the landfill.
Monitoring of the leachate generated from a landfill
site ensures that:
n The leachate management system on site is
operating as designed
n Detail on the waste decomposition is gathered
n Revision of the ground water and surface water
monitoring parameters if required
EPA licences specify the location, parameters and the
frequency of leachate monitoring. Typical requirements
in the licences for MSW landfills are monthly, quarterly
and annual monitoring for parameters such as the
leachate level, pH, conductivity, temperature, ammonia,
chloride, BOD/COD, total oxidised nitrogen, total
phosphate, metals, sulphates and fluoride. Monitoring
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the leachate levels is important within the waste body
to ensure that the leachate head (level above the basal
liner) is successfully controlled. The volume of leachate
discharged or transported from the landfill site must
be recorded on an ongoing basis and reported in the
annual environmental report.
9.6 Landfill gas
The Directive requires that landfill gas monitoring
must be representative for each section of the landfill.
The individual EPA licences specify the locations,
frequencies and the parameters that must be
monitored within and outside the waste body. Location
of the monitoring points are identified individually on
each landfill site through detailed risk assessment that
includes assessment of:
n Geology of site
n Type of waste
n Containment measures adopted
n Proximity of buildings and developments to the site
n Permeability of the waste
n Quality and volume of gas being generated
Requirements for MSW landfills include monitoring for
methane, carbon dioxide, oxygen, atmospheric pressure
and temperature at different frequencies at specified
locations within and outside the waste body. Landfill
gas where practicable is collected from MSW sites and
is either converted to energy or flared. Continuous
monitoring of the gas flow rate, temperature, carbon
monoxide, methane, carbon dioxide and oxygen with
annual monitoring for other parameters is required for
enclosed flares.
EPA licences set out gas trigger levels values that once
exceeded must have controls implemented and the
hazard contained. Identification of background levels
is important in the establishment of the trigger levels
as geology can impact on the methane and carbon
dioxide background level. However, in the absence
of background levels the EPA licences specify the
following trigger levels:
n Methane greater than or equal to 1 % v/v
n Carbon dioxide greater than or equal to 1.5%
The landfill operator must record any exceedences of
trigger levels and notify the EPA.
It should be noted that the EPA has initiated a number
of developments relating to landfill gas surface emissions
monitoring and increased monitoring will be required in
future (Chapter 8). In addition, greater emphasis will be
placed on balancing of the landfill gas field.
Figure 9.3Landfill gas monitoring
9.7 Odour
EPA licences for MSW landfills require operators to
undertake monitoring for odour. However, this is an
area that has undergone significant development in
recent years. Licence conditions at a number of landfills
have been reviewed to include stricter requirements to
control and monitor odorous gases (Chapter 8).
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9.8 Meteorological
Meteorological monitoring is an integral part of the
overall management of a landfill. Meteorological
information is obtained from on-site weather stations
or Met Éireann data or a combination of both. The
Metrological data assists in a number of ways in
the management of a landfill, e.g. information on
precipitation can be used to predict leachate and
landfill gas generation and information on wind speed
and direction is relevant to litter and odour control.
9.9 Stability & topography
A specific requirement outlined in the Landfill Directive
is to complete a topographical study of the landfill.
This is to include an annual review of the structure and
composition of the landfill body as well as the settling
behaviour of the landfill. During 2008, 29 of the MSW
landfills completed topographical surveys, which were
submitted as part of the Annual Environmental Report
for that reporting period. Three of the open IPPC
landfills completed the survey.
9.10 Noise
The following noise limits are generally specified in
EPA licences unless site-specific circumstances dictate
otherwise:
n 55 dB(A) LAeq(30 minutes) (Daytime)
n 45 dB(A) LAeq(30 minutes) (Night time)
Landfill operators are required to monitor noise at least
annually. There were 30 noise complaints in relation to
waste licensed landfills in 2009, though the majority
(24) related to a single landfill: Knockharley Landfill.
Figure 9.4Noise monitoring
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9.11 Dust
The following dust limit is specified in EPA licences:
n 350 mg/m2/day
Landfill operators are required to monitor dust
continuously using the Bergerhoff Instrument which
consists of a collecting bottle mounted on a 2m pole.
Figure 9.5Dust monitoring
9.12 EPA enforcement of monitoring requirements
A review of monitoring carried out at MSW landfills in
1995 showed that:
n 29.5% carried out leachate monitoring
n 7.4% carried out landfill gas monitoring
n 42.1% carried out some level of surface water
monitoring with the number of samples varying
from one sample to 95 samples per site
n 18.9% carried out some level of groundwater
monitoring with the number of samples varying
from one to 72 samples per site and the number
of sampling points ranging from one to 19 per site
EPA licensing and enforcement has led to a much
improved situation in 2009 with all landfills conducting
extensive leachate, landfill gas, surface water and
groundwater monitoring and in addition monitoring
of odours, noise, dust/particulate matter, ecology
and landfill stability and topography as appropriate.
Nonetheless, in 2008/2009, the EPA issued 94 non-
compliances related to monitoring. In general, these
relate to failure to monitor all parameters, or at the
specified frequencies or at all monitoring points rather
than complete systematic monitoring failures. Common
issues that arise include:
n Inadequate flare monitoring
n Telemetry systems not linked to aspects of the
monitoring network such as leachate level
monitors
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10. Closure, aftercare & financial provision
Landfill Directive
Article 8 requires that:
Adequate provisions, by way of a financial security or any other equivalent…will be made…prior to the
commencement of disposal operations to ensure that the obligations (including after-care provisions) arising…
are discharged and that the closure procedures…are followed.
Article 10 requires that:
All of the costs involved in the setting up and operation of a landfill site, including as far as possible the cost
of the financial security….and the estimated costs of the closure and after-care of the site for a period of
at least 30 years shall be covered by the price to be charged by the operator for the disposal of any type of
waste in that site…
Article 13 requires that:
…a landfill or part of it shall start the closure procedure
n when the relevant conditions stated in the permit are met; or
n under the authorisation of the competent authority, at the request of the operator; or
n by reasoned decision of the competent authority.
A landfill or part of it may only be considered as definitely closed after the competent authority has carried
out a final on-site inspection, has assessed all the reports submitted by the operator and has communicated
to the operator its approval for the closure. This shall not in any way reduce the responsibility of the operator
under the conditions of the permit
After a landfill has been definitely closed, the operator shall be responsible for its maintenance, monitoring
and control in the after-care phase for as long as may be required by the competent authority, taking into
account the time during which the landfill could present hazards
For as long as the competent authority considers that a landfill is likely to cause a hazard to the environment
and without prejudice to any Community or national legislation as regards liability of the waste holder, the
operator of the site shall be responsible for monitoring and analysing landfill gas and leachate from the site
and the groundwater regime in the vicinity of the site in accordance with Annex III
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10.1 Introduction
Following cessation of waste disposal, landfills continue
to pose an environmental risk and as such require
proper closure, restoration and aftercare to minimise
environmental impact. Landfills that are subject to high
standards of closure, restoration and aftercare have
the potential to provide amenity value, e.g. through
the development of sports pitches or areas of nature
conservation. Significant investment is required to
fund the closure, restoration and aftercare of a landfill
and it is important that adequate financial provision
is made. Cork City Council report that the cumulative
investment to end of 2008 for the closure of the
Kinsale Road Landfill was in excess of €20 million and
further expense will be incurred until the landfill no
longer poses an environmental risk.
10.2 Implementation of closure, aftercare & financial provision requirements
On foot of the Environmental Protection Agency
Act, 1992 and subsequently the Waste Management
Act, 1996, the Environmental Protection Agency
(EPA) specified criteria for landfill sites. One of the
technical documents published in 1999 was guidance
on landfill restoration and aftercare which deals with
restoration design, afteruse, soils handling, vegetation
establishment and the production of site specific
restoration and aftercare management plans.7 The
EPA initially commenced licensing of IPPC landfills in
1995 and the first waste license (MSW, inert and mono
landfills are covered by waste licenses) for a landfill was
granted in 1998. Requirements for financial provision
for closure and aftercare were included in all waste
licences and also became incorporated into the IPPC
landfill licenses over time. All operating landfills were
licensed by 2003. In 2002, a review of compliance
indicated that there was a lack of technical guidance
in relation to financial provision and this led to the
development of EPA guidance on Environmental
Liability Risk Assessment (ELRA), Residuals Management
Plans (RMP) and Financial Provision (FP) which was
supplemented with further EPA guidance in 2006.52
The ELRA/RMP/FP guidance provides a framework
for assessing environmental liabilities associated with
a site and guidance on financial provision. It was
supplemented by training provided to licensees in its
use and meetings with the financial sector to stimulate
the market in relation to the provision of financial
products to meet the licence requirements.
Assessment of landfill conditioning plans has led to
the strengthening of conditions relating to financial
liabilities, as part of the recent licence review process,
to ensure all environmental liabilities are addressed at
landfills and that charges in respect of the disposal of
waste are sufficient to meet the total costs necessary
for:
n the costs incurred by the operator in the
acquisition or development of the facility
n the costs of operating the facility
n the estimated costs of the closure, restoration,
remediation or aftercare of the facility
The EPA conducted further surveys on environmental
liability risk assessment and financial provision at
licensed sites in 2008. Furthermore, due to falling
landfill gate fees (from an average of €150/tonne53
in 2004 to €100/tonne in 2008) and poor levels of
compliance in relation to the furnishing of financial
information, the EPA issued a template form to 28
MSW landfill operators in 2009 for the submission of
annual financial statements. This gathered valuable
information in relation to the financial systems at
landfills, in particular in relation to the charging
structures and whether financial provision was being
made for closure, restoration and aftercare. As a result
of this survey, the EPA issued notifications of non-
compliance to 16 landfills and has requested further
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information from an additional nine. This enforcement
work is ongoing and is a priority in 2010. Further
enforcement action will be taken in situations where
the EPA is not satisfied that adequate provision is being
made for closure and aftercare.
The EPA established an Environmental Liability Unit
in 2009 tasked with the implementation of the
Environmental Liability Directive and other related
duties including the coordination of the assessment
of closure plans, aftercare and financial provision
requirements, contaminated land, remediation
and the costing of damage to the environment.
The Environmental Liability Unit adds to the EPA’s
capacity to give technical advice and guidance to
licensees about their obligations and will assist in the
EPA’s enforcement programme to ensure that those
obligations are met. The Environmental Liability Unit
is actively reviewing ELRA, RMP and FP methodologies
including provision at landfills.
Figure 10.1Restored landfill cell
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11 Action plan
The EPA has identified seven priorities for the landfill
sector that need to be tackled. These are in the
following aspects of landfill management:
n Diversion of BMW
n Landfill gas
n Legacy landfills
n Environmental liabilities and financial provision
n Cover and capping
n Leachate management
n Waste acceptance
This chapter sets out the issues in more detail, identifies
the actions that have already been taken and presents
an action plan to ensure these issues are tackled going
forward.
Significant measures have already been taken to
address these challenges. The key stakeholders are
landfill operators and they need to examine their
activities in light of the issues highlighted in this
report and take its findings into account. The EPA will
continue its work towards meeting the challenges
and will continue to collaborate with all stakeholders
(e.g. other state agencies, local communities and
licensees) to help foster a common understanding of
the problems and interventions necessary to meet the
challenges ahead.
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Diversion of BMW
Issues
n Landfilling of BMW results in high emissions of methane which is a greenhouse gas and a potential
source of odour nuisance.
n Ireland faces daily fines for non-compliance with Landfill Directive targets for diversion of BMW from landfill.
nAlmost 1.2 million tonnes of BMW were landfilled in 2008; just 0.916 million tonnes can be landfilled in
2010, reducing to 0.610 million tonnes in 2013 and 0.427 million tonnes in 2016.
Actions Taken
nPublication by the EPA in 2008 of Hitting the Targets for Biodegradable Municipal Waste: Ten Options
for Change.
nPublication by the EPA in 2009 of Municipal Solid Waste – Pre-Treatment & Residuals Management
including a stabilisation standard for waste.
nMajor conference organised in October 2009 dealing with the topic (presentations available on www.epa.ie).
nTwenty-five revised landfill licences issued by the EPA in 2009/early 2010 limiting the disposal of BMW
at landfill.
nPublication of the Food Waste Regulations in 2009.
nMinister of the Environment, Heritage and Local Government circular regarding the roll-out of brown bins.
What Else Needs To Be Done
nThe EPA will complete waste characterisation surveys at approximately 20 waste treatment facilities in 2010.
nThe EPA will develop a protocol for waste characterisation surveys.
nThe EPA will develop a robust system for reporting BMW disposal at landfills.
n Landfill operators must fully understand the nature of waste disposed at their landfill.
nThe waste sector must provide adequate capacity for collection and treatment of BMW.
n Local Authorities must implement the DEHLG Circular on roll-out of brown bins and enforce the Food
Waste Regulations.
nThe recommendations of the National Waste Report regarding diversion of BMW must be implemented.
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Landfill Gas
Issues
nThe landfilling of waste produces landfill gas which poses an environmental risk if not managed properly.
n Landfill gas must either be collected and used to produce energy, or flared according to EPA guidance.
n Landfill gas is odorous and accounted for 71% of all complaints in relation to licensed facilities in 2009.
Actions Taken
n Implementation of the licensing system has led to major improvements in terms of containment,
collection and flaring/utilisation of landfill gas – emissions of greenhouse gas from landfills decreased by
20% from 1990 to 2008.
nThe EPA has reviewed MSW landfill licences to ensure that odour management planning and control is
carried out in the most comprehensive manner.
nExtensive landfill gas and odour assessments are carried out by landfill operators and the EPA.
nThe EPA took 13 successful prosecutions in relation to landfill gas management and odour impact, and
submitted three files to the Director of Public Prosecutions (DPP) in 2009.
What Else Needs To Be Done
n Landfill operators must implement the recommendations of EPA reports on landfill gas emissions and
management systems.
n Landfill operators must implement an odour management plan approach to ensure that their facilities do
not cause odour nuisance.
nThere appears to be greater scope to use landfill gas and landfill operators should examine the feasibility
of utilisation of landfill gas.
n Landfill operators must limit intake of BMW in compliance with licence conditions.
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Legacy Landfills
Issues
nThere are over 300 landfills that were operated by local authorities between 1977 and 1997 without
specific authorisation and which must now be regularised under the Historic Unlicenced Waste Disposal
and Recovery Activity Regulations.
Actions Taken
nThe EPA published a Code of Practice for risk assessment of legacy landfills in 2007.
nThe EPA established an electronic register and GIS based risk assessment tool for legacy landfills in 2009.
nThe DEHLG funded a pilot project (involving Local Authorities) on environmental risk assessment of legacy
landfills in 2009/2010.
nThe EPA developed decision matrices to ensure site investigations are carried out to the standards
required under the Code of Practice.
nThe authorisation process for legacy landfills has commenced.
What Else Needs To Be Done
n Local Authorities must ensure all legacy landfills have been identified and registered.
n Local Authorities must ensure all legacy landfills are risk assessed and applications made for authorisation.
n Local Authorities must implement remediation actions in accordance with risk assessments and EPA
authorisations.
nAdditional DEHLG funding for risk assessments should be directed to high and moderate risk landfills as a
priority.
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Office of Environmental Enforcement (OEE)
Environmental Liabilities & Financial Provision
Issues
n Landfills continue to pose an environmental risk after closure and require proper closure, restoration and
aftercare to minimise environmental impact.
nSignificant financial provision is required to fund closure, restoration and aftercare costs.
n Landfill gate fees have declined by one third between 2004 and 2008 which raises concerns in relation to
funding of closure, restoration and aftercare costs in particular.
Actions Taken
nThe EPA issued guidance on landfill restoration and aftercare in 1999 and environmental liabilities
management in 2006.
nThe EPA initiated enforcement actions in relation to financial systems at open MSW landfills in 2009.
nThe EPA established an Environmental Liabilities Unit.
What Else Needs To Be Done
n Landfill operators must ensure that the closure/aftercare plans are in place that are fully compliant with
EPA requirements and that these plans are properly costed and financed.
n Landfill operators must ensure that the price charged for disposal of waste is sufficient to cover the costs
of set-up, operation and closure/aftercare of the landfill.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Cover & Capping
Issues
nThe proper covering and capping of landfilled waste are critical to the successful prevention of nuisance
and control of landfill gas and leachate.
nAlthough cover was applied at all landfills in 2008, a survey found that it was only applied correctly at 50%.
nAlthough there has been significant improvement in capping of landfills since licensing, non-compliances,
in particular with capping/restoration deadlines, are still occurring.
Actions Taken
nThe EPA presented cover best practice at a conference for landfill operators in October 2009
(presentations available on www.epa.ie).
nCover management plans are now being required at landfills.
nThe EPA enforces capping requirements on an ongoing basis and two landfills were prosecuted on
indictment for failure to install capping.
What Else Needs To Be Done
nThe EPA will develop guidance on landfill cover in 2010.
n Landfill operators must implement best practice is relation to cover in order to prevent nuisance.
n Landfill operators must carry out capping works in strict compliance with approved plans and in a timely
manner.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Leachate Management
Issues
n Landfill leachate poses an environmental risk to ground and surface water if not properly controlled.
nApproximately 1.4 million cubic metres of leachate was collected at landfills in 2008.
n99% of collected leachate was treated at off-site Urban Wastewater Treatment Plants.
nThere were reoccurring failures during 2008 and 2009 to maintain leachate levels less than the required
1m above the base of landfills.
Actions Taken
n Implementation of the licensing system has led to major improvements in terms of minimising and
managing leachate – 100% of open MSW landfills are now lined and are collecting the contained
leachate for treatment.
nThe introduction of an EPA authorisation system for urban wastewater treatment plants in December 2007
is resulting in greater control on discharges from urban wastewater treatment plants taking leachate.
nThe EPA took nine successful prosecutions in relation to inadequate leachate management.
What Else Needs To Be Done
nThe need for urban wastewater treatment plants to meet authorisation requirements may limit their
capacity to treat landfill leachate and on-site treatment of landfill leachate may become increasingly
necessary in the future. Landfill operators need to be aware of this issue and plan accordingly.
n Landfill operators shall manage leachate in full compliance with licence requirements.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Waste Acceptance
Issues
n It is important that proper waste acceptance procedures are in place to ensure that waste is disposed
of in the correct class of landfill (inert, non-hazardous or hazardous).
nThere is a lack of hazardous waste landfill capacity in Ireland.
nGypsum waste co-disposed with organic waste can break down into hydrogen sulphide gas, which is
colourless, toxic and flammable and can lead to odour nuisance.
Actions Taken
nThe EPA developed guidance on waste classification and implemented European waste acceptance
requirements through its licensing system.
nAll landfills now maintain extensive records of waste accepted at their facilities.
nThe EU completed a survey of waste acceptance at landfills in 2009.
nThe EPA commissioned a study in 2009 to examine the provision of hazardous waste landfill capacity
in Ireland.
nThe EPA engaged extensively with all stakeholders in relation to prevention of inappropriate landfill
of gypsum waste and piloted a method for measuring gypsum in waste going to landfill.
What Else Needs To Be Done
n Landfill operators must implement strict waste acceptance procedures to ensure only appropriate wastes
are accepted into landfills.
nThe recommendations of the National Hazardous Waste Management Plan with respect to provision
of hazardous landfill capacity must be implemented.
nThe Construction & Demolition waste sector (producers, transfer stations, landfill operators) should
segregate gypsum waste at source for recovery. Gypsum waste should not be landfilled with
biodegradable waste.
n Ireland needs to continue to monitor EU developments in relation to waste acceptance. The EPA will
develop further guidance on waste acceptance.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
References
1. Council Directive 1999/31/EC of 26 April 1999
on the landfill of waste. Official Journal of the
European Communities L 182, 16/07/1999.
2. Council Directive of 15 July 1975 on waste
(75/442/EEC). Official Journal of the European
Communities L 194, 25/07/1975.
3. Environmental Protection Agency (1995) Landfill
Manuals: Investigations for Landfills. EPA, Wexford.
4. Environmental Protection Agency (1995) Landfill
Manuals: Landfill Monitoring. EPA, Wexford.
5. Environmental Protection Agency (2003) Landfill
Manuals: Landfill Monitoring, 2nd Edition. EPA,
Wexford.
6. Environmental Protection Agency (1997) Landfill
Manuals: Landfill Operational Practices. EPA,
Wexford.
7. Environmental Protection Agency (1999) Landfill
Manuals: Landfill Restoration and Aftercare. EPA,
Wexford.
8. Environmental Protection Agency (2000) Landfill
Manuals: Landfill Site Design. EPA, Wexford.
9. Council Decision (2003/33/EC) of 19 December
2002 establishing criteria and procedures for the
acceptance of waste at landfills pursuant to Article
16 of and Annex II to Directive 1999/31/EC. Official
Journal of the European Communities L 11/27,
16/01/2003.
10. Directive 2006/21/EC of The European Parliament
and of the Council of 15 March 2006 on the
management of waste from extractive industries
and amending Directive 2004/35/EC. Official
Journal of the European Communities L 102/15,
11/04/2006.
11. Directive 2004/35/CE of the European
Parliament and of the Council of 21 April 2004
on environmental liability with regard to the
prevention and remedying of environmental
damage. Official Journal of the European
Communities L 143/56, 30/04/2004.
12. An Foras Forbartha (1986) National Database on
Waste.
13. Environmental Protection Agency (1998) Local
Authority Landfill Sites in Ireland: A Report for
1995 – 1997. EPA, Wexford.
14. Environmental Protection Agency (1996) National
Waste Database Report 1995. EPA, Wexford.
15. Environmental Protection Agency (2000) National
Waste Database Report 1998. EPA, Wexford.
16. Environmental Protection Agency (2003) National
Waste Database Report 2001. EPA, Wexford.
17. Environmental Protection Agency (2004) National
Waste Database Interim Report 2002. EPA,
Wexford.
18. Environmental Protection Agency (2004) National
Waste Database Interim Report 2003. EPA,
Wexford.
19. Environmental Protection Agency (2005) National
Waste Report 2004. EPA, Wexford.
20. Environmental Protection Agency (2006) National
Waste Report 2005: Data Update. EPA, Wexford.
21. Environmental Protection Agency (2007) National
Waste Report 2006. EPA, Wexford.
22. Environmental Protection Agency (2009) National
Waste Report 2007. EPA, Wexford.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
23. Environmental Protection Agency (2009) National
Waste Report 2008. EPA, Wexford.
24. European Environment Agency (2009) Diverting
Waste from Landfill: Effectiveness of Waste
Management Policies in the European Union. EEA,
Copenhagen.
25. Department of the Environment and Local
Government (1998) Waste Management:
Changing our Ways. Department of Environment,
Heritage and Local Government, Dublin.
26. Environmental Protection Agency (2007) CODE OF
PRACTICE – Environmental Risk Assessment for
Unregulated Waste Disposal Sites. EPA, Wexford.
27. Department of Environment, Heritage and
Local Government (2006) National Strategy on
Biodegradable Waste. DEHLG, Dublin.
28. Environmental Protection Agency (2009) Ireland:
National Inventory Report 2009: Greenhouse
Gas Emissions 1990 – 2007: Reported to the
United Nations Framework Convention on Climate
Change. EPA, Wexford.
29. Environmental Protection Agency (2009)
Municipal Solid Waste; Pre-treatment & Residuals
Management: An EPA Technical Guidance
Document. EPA, Wexford.
30. Environmental Protection Agency (2008) Hitting
the Targets for Biodegradable Municipal Waste:
Ten Options for Change. EPA, Wexford.
31. Environmental Protection Agency (2010) Waste
Licence W0001-04, Kerry County Council, North
Kerry Landfill Site – Granted 24/03/2010. EPA,
Wexford.
32. Environmental Protection Agency (2009) Protocol
for the Evaluation of Biodegradable Municipal
Waste sent to Landfill by Pretreatment Facilities
(DRAFT). EPA, Wexford.
33. Department of Environment, Heritage and Local
Government (2009) Circular WPPR 17/08: National
Strategy on Biodegradable Waste: Implementation
of Segregated “Brown Bin” Collection for
Biowaste and Home Composting. Department of
Environment, Heritage and Local Government,
Dublin.
34. European Commission and BiPRO (2009) Assessing
Legal Compliance with and Implementation of the
Waste Acceptance Criteria and Procedures by the
EU-15. European Commission, Brussels.
35. Environmental Protection Agency (2008) National
Hazardous Waste Management Plan 2008-2012.
EPA, Wexford.
36. Environmental Protection Agency (2001) National
Hazardous Waste Management Plan. EPA,
Wexford.
37. Environmental Protection Agency (2008)
Waste Licence W0129-02, Murphy Concrete
Manufacturing Ltd. – Granted 21/05/2008. EPA,
Wexford.
38. Environmental Protection Agency (2002) European
Waste Catalogue and Hazardous Waste List – Valid
From 1 January 2002. EPA, Wexford.
39. Clean Technology Centre (2004) Procedure for
the Identification of the Hazardous Components
of Waste & Hazardous Waste Classification
Worksheet. EPA, Wexford.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
40. Environmental Protection Agency (2006) Focus
on Environmental Enforcement 2004-2005. EPA,
Wexford.
41. Environmental Protection Agency (2009) Focus on
Environmental Enforcement in Ireland – A Report
for the Years 2006-2008. EPA, Wexford.
42. South Dublin County Council. <http://www.
arthurstown.com/facts.htm> Viewed on
28/07/2009.
43. Odour Monitoring Ireland (unpublished)
Independent Assessment of the Adequacy
and Suitability of Various Alternative Daily and
Intermediate Cover Materials at EPA Licensed
Landfills in Ireland. EPA, Wexford.
44. Environmental Protection Agency (2010) Ireland’s
Greenhouse Gas Emissions in 2008. EPA, Wexford.
45. Environmental Protection Agency (2010) Ireland
– National Inventory Report 2010 – Greenhouse
Gas Emissions 1990 – 2008 Reported to the
United Nations Framework Convention on Climate
Change. EPA, Wexford.
46. Sustainable Energy Ireland (2004) Renewable
Energy Resources in Ireland for 2010 and 2020 – A
Methodology. Sustainable Energy Ireland, Dublin.
47. Environment Agency (2004) LFTGN 03: Guidance
on the Management of Landfill Gas. Environment
Agency, Bristol, UK.
48. Dublin City Council et. al (2005) Dublin
Waste Management Plan 2005-2010. <http://
dublinwaste.ie> Viewed on 04/08/2009.
49. Eamonn Rogers (2009) Power Generation in
Ireland using Landfill Gas: Today and Tomorrow.
Presentation at: Sherkin Island Marine Station 25th
Annual Environmental Conference: Energy from
Waste. Cork, 08/05/2009.
50. Environmental Protection Agency (2010) Summary
Report – Independent Assessment of Landfill Gas
Emissions and Management Systems at 29 EPA
Licensed landfills in the Republic of Ireland. EPA,
Wexford.
51. Environmental Protection Agency (2010)
Air Guidance Note 5 (AG5) - Odour Impact
Assessment Guidance for EPA Licensed Sites.
EPA, Wexford.
52. Environmental Protection Agency (2006) Guidance
on Environmental Liability Risk Assessment,
Residuals Management Plans and Financial
Provision. EPA, Wexford.
53. Environmental Protection Agency (2005) The
Nature and Extent of Unauthorised Waste Activity
in Ireland. EPA, Wexford.
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Office of Environmental Enforcement (OEE)
Appendix 1 Legal & regulatory framework
1975–Waste Framework Directive
The original Waste Framework Directivea was adopted
in 1975 and required any facility treating, storing or
tipping waste on behalf of third parties to obtain a
permit specifying:
n the type and quantity of waste to be treated
n the general technical requirements
n the precautions to be taken
n the information to be made available at the
request of the competent authority concerning the
origin, destination and treatment of waste and the
type and quantity of such waste
Member States were required to bring the 1975 Waste
Framework Directive into force by 15/07/1977. The
2008 Waste Framework Directiveb will replace the
1975 Waste Framework Directive (and its amendments)
when it comes into force on 12/12/2010.
1979–Waste Regulations
The European Communities (Waste) Regulations,
1979 [S.I. No. 390/1979] came into operation on the
01/04/1980 and gave effect to the requirements of the
1975 Waste Framework Directive. These Regulations
stipulated that a person other than a local/sanitary
authority shall not carry out the treating, storing or
tipping of waste on behalf of another person without
an appropriate permit from a local authority. This
permit system was superseded by the requirements of
the Waste Management Act, 1996.
a Council Directive of 15 July 1975 on waste (75/442/EEC). Official Journal of the European Communities L 194, 25/07/1975.
b Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and repealing certain Directives. Official Journal of the European Communities L 312/3, 22/11/2008.
1992–Environmental Protection Agency Act
The Environmental Protection Agency Act, 1992
established the EPA and required it to specify and
publish criteria for the selection, management,
operation and termination of landfill sites. These were
published as follows:
n 1995–Investigations for landfillsc
n 1995 updated 2003–Landfill monitoringd,e
n 1997–Landfill operational practicesf
n 1999–Landfill restoration and aftercareg
n 2000–Landfill site designh
Local authorities were required to operate their landfills
in accordance with the criteria specified by the EPA, to
monitor their landfills and to submit the monitoring
results to the EPA. The Act also required the EPA to
publish reports on the operation of local authority
landfill sites from time to time.
The EPA commenced integrated pollution control
(IPC) licensing under the Act in 1994 and any landfills
associated with IPC activities became regulated under
the IPC licence, e.g. landfills for disposal of ash from
power plants.
c Environmental Protection Agency (1995) Landfill Manuals: Investigations for Landfills. EPA, Wexford.
d Environmental Protection Agency (1995) Landfill Manuals: Landfill Monitoring. EPA, Wexford.
e Environmental Protection Agency (2003) Landfill Manuals: Landfill Monitoring, 2nd Edition. EPA, Wexford.
f Environmental Protection Agency (1997) Landfill Manuals: Landfill Operational Practices. EPA, Wexford.
g Environmental Protection Agency (1999) Landfill Manuals: Landfill Restoration and Aftercare. EPA, Wexford.
h Environmental Protection Agency (2000) Landfill Manuals: Landfill Site Design. EPA, Wexford.
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Office of Environmental Enforcement (OEE)
The Environmental Protection Agency Act, 1992 was
amended by the Protection of the Environment Act,
2003. The IPC licensing system was updated to an
Integrated Pollution Prevention Control (IPPC) licensing
system to give effect to the IPPC Directive.i
1996–Waste Management Act
The Waste Management Act, 1996 introduced the
licensing of stand-alone landfills. Prescribed dates for
waste licence applications were specified in the Waste
Management (Licensing) Regulations, 1997 [S.I. No.
133/1997] and varied from 01/05/1997 to 01/03/1999
depending on whether the activity was existing or new,
whether it was operated by a local authority or private
body and its size. The first applications for landfills were
received by the EPA on 30/04/1997.
The Waste Management Act, 1996 also expanded on
the existing requirement for local authorities to make
waste management plans. Plans have been prepared
on a regional basis. Further information on waste
management planning, including a national overviewj,
is available on:
http://www.environ.ie/en/Environment/Waste/
The Act also required the EPA to make a national
hazardous waste management plan. The current
national hazardous waste management plan covers the
years 2008 to 2012k and is available on:
http://www.epa.ie/downloads/pubs/waste/haz/
name,25129,en.html
i Council Directive 96/61/EC of 24 September 1996 concerning integrated pollution prevention and control. Official Journal of the European Communities L 257, 10/10/1996.
j Department of Environment, Heritage and Local Government (2004) National Overview of Waste Management Plans. DEHLG, Dublin.
k Environmental Protection Agency (2008) National Hazardous Waste Management Plan 2008-2012. EPA, Wexford.
2001–Landfill Directive
Council Directive 1999/31/EC of 26 April 1999 on the
landfill of waste (referred to herein as the ‘Landfill
Directive’), was published on the 16/07/1999 and
Member States were required to bring it into force
by 16/07/2001.l The overall objective of the Landfill
Directive is:
by way of stringent operational and technical
requirements on the waste and landfills, to provide
for measures, procedures and guidance to prevent
or reduce as far as possible negative effects on the
environment, in particular the pollution of surface
water, groundwater, soil and air, and on the global
environment, including the greenhouse effect, as
well as any resulting risk to human health, from
landfilling of waste, during the whole life-cycle of
the landfill [Article 1(1)]
The Landfill Directive details requirements for landfill
classification, waste acceptance, permitting, design,
control, monitoring, financial provision, closure and
aftercare. It also sets targets for the diversion of
biodegradable municipal waste from landfill. Existing
landfills (i.e. those already permitted or in operation at
the time of transposition of the Landfill Directive) were
required to be assessed vis a vis the requirements of the
Landfill Directive and either closed or brought into line
with Landfill Directive standards by 16/07/2009.
2002 – Waste Acceptance Decision
Council Decision 2003/33/EC of 19 December 2002
establishing criteria and procedures for the acceptance
of waste at landfills pursuant to Article 16 of and
Annex II to Directive 1999/31/EC came into force on
16/07/2004 and Member States were required to
l Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste. Official Journal of the European Communities L 182, 16/07/1999.
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Office of Environmental Enforcement (OEE)
apply the criteria therein by 16/07/2005.m The Decision
expands on the waste acceptance criteria specified
in the Landfill Directive and sets detailed criteria for
waste characterisation and acceptance at each class of
landfill: inert, non-hazardous and hazardous.
2002–Waste Licensing Regulations
The Waste Management Licensing (Amendment)
Regulations, 2002 [S.I. No. 336 of 2002] and European
Communities (Amendment of Waste Management
(Licensing) Regulations 2000) Regulations, 2002 [S.I. No.
377 of 2002] transpose the requirements of the Landfill
Directive in Ireland. They require the EPA to give effect to
specific requirements of the Landfill Directive in landfill
licences and explicitly address landfill classification and
aspects of waste acceptance and financial provision.
They also provide a framework to address existing
landfills as required by the Landfill Directive. These
Regulations came into effect on 02/06/2002 and have
been replaced by the Waste Management Licensing
Regulations, 2004 [S.I. No. 395 of 2004].
2006 – Extractive Waste Directive
Directive 2006/21/EC of the European Parliament and
of the Council of 15 March 2006 on the management
of waste from extractive industriesn came into force on
the 01/04/2006 and applies to:
the management of waste resulting from the
prospecting, extraction, treatment and storage
of mineral resources and the working of quarries
[Article 2(1)]13
Waste that falls under this Directive is not subject to
the Landfill Directive.
m Council Decision (2003/33/EC) of 19 December 2002 establishing criteria and procedures for the acceptance of waste at landfills pursuant to Article 16of and Annex II to Directive 1999/31/EC. Official Journal of the European Communities L 11/27, 16/01/2003.
n Directive 2006/21/EC of The European Parliament and of the Council of 15 March 2006 on the management of waste from extractive industries and amending Directive 2004/35/EC. Official Journal of the European Communities L 102/15, 11/04/2006.
2008 – Historic Unlicenced Waste Disposal and Recovery Activity Regulations
The Waste Management (Certification of Historic
Unlicenced Waste Disposal and Recovery Activity)
Regulations, 2008 [S.I. No. 524 of 2008] came into
effect on 08/12/2008. These Regulations address a gap
in transposition of the 1975 Waste Framework Directive
under the 1979 Waste Regulations in that local
authorities were not required to have authorisation for
their waste management activities. These regulations
also respond to the findings of the European Court
of Justice in its ruling of 26/04/2005 against Ireland
regarding failure to implement the Waste Framework
Directive (Case C-494/01). The regulations require
local authorities to carry out the following in relation
to the landfills they operated without a waste licence
between 15/07/1977 and 27/03/1997 (referred to as
‘closed landfills’):
n identify all closed landfills by 30/06/2009
n maintain a register of closed landfills
n carry out a risk assessment of closed landfills
n apply to the EPA for a certificate of authorisation
for closed landfills
Local authorities are required to have regard to the
Code of Practice–Environmental Risk Assessment for
Unregulated Waste Disposal Siteso in identifying and
risk assessing closed landfills.
The EPA certificate of authorisation must determine
the adequacy of the risk assessment, specify necessary
measures for protection of human health, the
environment and compliance with European law, and
require a remediation validation report.
o Environmental Protection Agency (2007) CODE OF PRACTICE – Environmental Risk Assessment for Unregulated Waste Disposal Sites. EPA, Wexford.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
2008 – Environmental Liability Regulations
The European Communities (Environmental Liability)
Regulations, 2008 implement Directive 2004/35/EC
of the European Parliament and of the Council of 21
April 2004 on environmental liability with regard to the
prevention and remedying of environmental damage.p
The Regulations came into operation on 01/04/2009
and apply inter alia to facilities licensed by the EPA. The
Regulations are designed to discourage environmental
damage and make operators liable for preventing
and remedying any damage caused. The EPA is the
competent authority and its activities in this regard will
include:
n assessing/investigating cases of possible
environmental damage
n issuing remediation notices
n overseeing implementation of remediation notices
n taking further enforcement action where
appropriate
p Directive 2004/35/CE of the European Parliament and of the Council of 21 April 2004 on environmental liability with regard to the prevention and remedying of environmental damage. Official Journal of the European Communities L 143/56, 30/04/2004.
2009–Extractive Waste Regulations
The Waste Management (Management of Waste
from the Extractive Industries) Regulations, 2009 [S.I.
No. 566 of 2009] transpose the requirements of the
Extractive Waste Directive in Ireland. Waste that falls
under the Directive and these Regulations is not subject
to the Landfill Directive. Accordingly, a number of
waste management facilities in Ireland that formerly
fell under the Landfill Directive now fall under the
Extractive Waste Directive/Regulations instead, e.g.
tailing management facilities for mine tailings waste.
Best Available Techniques (BAT)
The EPA published draft landfill best available
techniques (BAT) guidance notes for comment in 2003
and 2008. BAT notes represent best practice and the
specifications in the BAT guidance notes apply to new
waste and IPPC landfills and existing waste and IPPC
landfills where the licences are reviewed.
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Appendix 2 List of landfills
Landfills open in 2009
Licence Reg.
No.
Licensee Name of Facility
Municipal solid waste (MSW) landfills
W0001-04 Kerry County Council North Kerry Landfill
W0004-04 South Dublin County Council Arthurstown Landfill
W0009-03 Fingal County Council Balleally Landfill
W0012-02 Cork City Council Kinsale Road Landfill*
W0017-04 Limerick County Council Gortadroma Landfill Site
W0020-02 Monaghan County Council Scotch Corner Landfill
W0021-02 Mayo County Council Derrinumera Landfill Facility
W0024-04 Donegal County Council Ballynacarrick Landfill Site
W0025-03 Carlow County Council Powerstown Landfill Site
W0026-03 Laois County Council Kyletalesha Landfill
W0028-03 Westmeath County Council Ballydonagh Landfill
W0029-03 Offaly County Council Derryclure Landfill
W0030-02 Kilkenny County Council Dunmore Landfill
W0047-02 Neiphin Trading Limited Kerdiffstown
W0059-03 Roscommon County Council Ballaghaderreen Landfill
W0060-03 Louth County Council Whiteriver Landfill Site
W0066-03 Wicklow County Council Rampere Landfill
W0067-02 Mayo County Council Rathroeen Landfill
W0068-03 Cork County Council Youghal Landfill
W0074-03 South Tipperary County Council Donohill Landfill
W0077-03 Cavan County Council Corranure Landfill
W0078-03 North Tipperary County Council Ballaghveny Landfill
W0081-03 KTK Landfill Limited KTK Landfill Limited
W0089-02 Cork County Council Derryconnell Landfill
W0146-02 Greenstar Holdings Limited Knockharley Landfill
W0165-02 Greenstar Holdings Limited Ballynagran Residual Landfill
W0201-03 Bord na Móna plc Drehid Waste Management Facility
W0109-02 Clare County Council Central Waste Management Facility
W0178-02 Greenstar Holdings Limited East Galway Residual Landfill Site
W0191-02 Wexford County Council Holmestown Waste Management Facility
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Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Licence Reg.
No.
Licensee Name of Facility
Inert landfills
W0048-01 Marrakesh Limited Kilmurry South
W0129-02 Murphy Environmental Hollywood Limited Murphy Environmental Hollywood Limited
W0151-01 Murphy Concrete Manufacturing Ltd Murphy Concrete Manufacturing Ltd
W0156-01 KTK Sand and Gravel Limited KTK Sand & Gravel Ltd
Mono landfills
W0037-01 Clare County Council Tradaree Point E.T.P.
W0049-02 Bord NaMona Clonbulloge Ash Repository
Integrated Pollution Prevention & Control (IPPC) landfills
P0027-02 Medite Europe Limited Medite Europe Limited
P0029-02 Irish Cement Limited Irish Cement Limited (Limerick)
P0030-03 Irish Cement Limited Irish Cement Limited (Drogeda)
P0376-01 Premier Periclase Limited Premier Periclase Limited
P0393-02 Kerry Ingredients (Ireland) Limited Kerry Ingredients (Ireland) Limited
P0419-01 Conoco Philips Bantry Bay Terminals Limited Conoco Philips Bantry Bay Terminals Limited
P0499-01 Bord NaMona Fuels Limited Bord NaMona Fuels Limited (Littleton)
P0519-02 Gypsum Industries Limited Gypsum Industries Limited*
P0605-02 Electricity Supply Board (Moneypoint) Coal Ash Landfill & FGD Landfill A**
P0610-01 Electricity Supply Board (Lough Ree Power) Electricity Supply Board (Lough Ree Power)
P0611-01 Electricity Supply Board (West Offaly Power) Electricity Supply Board (West Offaly Power)
*Closed during 2009
**Two open landfills on-site in 2009
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EPA licensed closed landfills in 2009
Licence Reg.
No.
Licensee Name of Facility
Municipal solid waste (MSW) landfills
W0002-02 Cork County Council Ballyguyroe Landfill Site
W0010-02 Meath County Council Basketstown Landfill Facility
W0011-01 Wicklow County Council Ballymurtagh Landfill Facility
W0013-01 Galway City Council Carrowbrowne Landfill Site
W0014-01 Kildare County Council Silliot Hill Landfill
W0015-01 Dun Laoghaire–Rathdown County Council Ballyogan Landfill Facility & Recycling park
W0016-02 Wexford County Council Killurin Landfill Site
W0018-01 Waterford City Council Kilbarry Landfill Site
W0022-01 Cork County Council East Cork Landfill Site
W0023-01 Cork County Council Raffeen Landfill Site
W0027-02 Ballinasloe Town Council Pollboy Landfill Facility
W0031-01 Clare County Council Doora Landfill Site
W0032-02 Waterford County Council Dungarvan Waste Disposal Site
W0033-01 Drogheda Borough Council Drogheda Landfill Site
W0034-02 Dundalk Town Council Dundalk Landfill & Civic Waste Facility
W0062-01 Donegal County Council Churchtown Landfill
W0063-01 Donegal County Council Drumabodan Landfill Site
W0064-01 Leitrim County Council Carrick-on-Shannon Landfill
W0065-01 Leitrim County Council Mohill Landfill
W0069-01 Kerry County Council Milltown Transfer Station
W0070-01 Cork County Council Benduff Landfill Site
W0071-02 Westmeath County Council Marlinstown Landfill
W0072-01 Kerry County Council Coolcaslagh Transfer Station
W0073-01 Roscommon County Council Roscommon Landfill Facility
W0075-02 Waterford County Council Tramore Waste Disposal Site
W0076-01 Limerick City Council Longpavement
W0086-01 Kerry County Council Kenmare Transfer Station
W0087-01 Kerry County Council Cahirciveen Transfer Station
W0090-01 Donegal County Council Balbane Landfill Site
W0091-01 Cavan County Council Bailieborough Landfill
W0092-01 Cavan County Council Belturbet Landfill
W0093-01 Cavan County Council Ballyjamesduff Landfill
W0125-01 Donegal County Council Glenalla Landfill Site
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Focus on Landfilling in Ireland
Page 79
Environmental Protection Agency
Office of Environmental Enforcement (OEE)
Licence Reg.
No.
Licensee Name of Facility
W0126-01 Donegal County Council Muckish Landfill Site
W0127-01 Fingal County Council Dunsink Landfill
W0139-01 Carlow County Council Haroldstown Transfer Station
W0170-01 Clare County Council Lisdeen Recycling Centre & Transfer Station
Inert landfills
W0053-03 Greenstar Limited Greenstar Limited
W0080-01 Carnegie J.W. & Co. Limited Dillonsdown
W0084-01 Hegarty Demolition Limited Aghfarrell
W0088-01 Paul Joyce Corbally
Mono landfills
W0046-01 Tegral Building Products Limited Ballylinan Landfill Site
W0199-01 Bord na Mona Energy Limited Srahmore Peat Deposition Site
Integrated Pollution Prevention & Control (IPPC) landfills
P0012-04 Roche Ireland Limited Roche Ireland Limited
P0022-02 Finsa Forest Products Limited Finsa Forest Products Limited
P0031-02 Holfield Plastics Ltd Holfield Plastics Ltd*
P0081-02 Irish Asphalt Limited Irish Asphalt Limited
P0222-01 Irish Sugar plc Irish Sugar plc (Carlow)**
P0223-01 Irish Sugar plc Irish Sugar plc (Cork)***
P0225-01 John Ronan & Sons John Ronan & Sons
P0389-01 Thornbrush Holdings Limited Thornbrush Holdings Limited
P0498-01 Irish Ispat Limited Irish Ispat Limited
P0516-01 Tara Mines Limited Tara Mines Limited
P0626-01 Electricity Supply Board (Shannonbridge) Electricity Supply Board (Shannonbridge)
P0627-01 Electricity Supply Board (Bellacorick) Electricity Supply Board (Bellacorick)
P0629-01 Electricity Supply Board (Lanesborough) Electricity Supply Board (Lanesborough)
Illegal landfills
W0181-01 Swalcliffe Ltd Swalcliffe Ltd
W0204-01 Brownfield Restoration Ireland Limited Brownfield Restoration Ireland Limited
W0213-01 Roadstone Dublin Limited Roadstone Dublin Remediation Landfill
* There are four closed landfills on this site
** There are two closed landfills on this site
*** There are six closed landfills on this site
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Focus on Landfilling in Ireland
Page 80
Environmental Protection Agency
Office of Environmental Enforcement (OEE)
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Focus on Landfi lling in Ireland
ENVIRONMENTAL PROTECTION AGENCY
An Ghníomhaireacht um Chaomhnú Comhshaoil
PO Box 3000, Johnstown Castle Estate, Co Wexford, Ireland
Telephone: +353-53-91-60600; Fax: +353-53-91-60699
E-mail: [email protected] Website: www.epa.ie
LoCall: 1890 335599
FOCUS ON LANDFILLING IN IRELANDThe Environmental Protection Agency
FOC
US O
N LA
ND
FILLING
IN IR
ELA
ND
The En
viron
men
tal Protectio
n A
gen
cy
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